This is the first in a series of articles in which we explore the tax rules applying to intra-group transactions. The basic proposition is that such transactions are tax neutral. This reflects the idea that a corporate group represents a single economic unit – when assets are transferred between members, ownership remains within the same family. Accordingly no tax is charged until such time that the asset leaves the group.
In this first article, we shall give an overview of what a corporate group looks like. Later articles will look at the actual rules governing intra-group transfers.
(This article can be downloaded in pdf format at Academia.edu.) Continue reading »