The Degrouping Rules and the Subgroup Exception – what does the legislation say?

 Corporate Groups, Corporate Tax, IP Tax  Comments Off on The Degrouping Rules and the Subgroup Exception – what does the legislation say?
Aug 232013
 

In our last article on corporate groups, we looked at the subgroup exception as it applies to intra-group transfers. We showed, using both numerical and visual examples, why there should be an exception. In this article we shall see how the tax legislation ensures that this is indeed the case. As before, we shall be concentrating on the rules for capital assets – the rules for IP are similar. Continue reading »