CG73840 - Non-Resident Capital Gains Tax (NRCGT) � Disposals on or after 6 April 2015 to 5 April 2019: Companies: Special rules: Pooling of NRCGT gains and losses
It has long been a principle of the system for charging capital gains that companies within a group may transfer assets between themselves on a tax neutral basis. »Ê¹ÚÌåÓýappy are allowed in effect to pool the assets of the group for tax purposes and pool gains and losses arising.
»Ê¹ÚÌåÓýapp CT legislation contains extensive provisions on groups of companies and pooling. »Ê¹ÚÌåÓýappse aim to ensure that pooling arrangements should only be available to companies that comply with their obligations and provide us with clear information. TCGA92/S188A to 188K build on this long established principle, by allowing non-resident companies which are part of a group to elect to pool losses and gains arising from the disposal of UK residential property.