The Degrouping Rules and the Subgroup Exception – an Overview

 Corporate Groups, Corporate Tax, IP Tax  Comments Off on The Degrouping Rules and the Subgroup Exception – an Overview
May 062013
 

As has been stated in previous articles, the degrouping rules are designed to prevent assets from being smuggled out of a group tax free under the protection of a corporate wrapper. This is achieved by imposing a tax liability when a company acquires an asset from a fellow group member and subsequently leaves the group within the next 6 years. 

But for every rule, there is an exception. Continue reading »

Corporate Tax Groups – Degrouping IP

 Corporate Groups, Corporate Tax, IP Tax  Comments Off on Corporate Tax Groups – Degrouping IP
Apr 212013
 

In this article, we shall discuss the degrouping rules as they apply to intangible assets such as IP and goodwill (collectively referred to as IP). The tax treatment is similar to that applying to capital assets, but with important differences.

(This article can be downloaded in pdf format at Academia.edu.) Continue reading »

Corporate Tax Groups – the Capital Gains Degrouping Rules – Part One

 Corporate Groups, Corporate Tax  Comments Off on Corporate Tax Groups – the Capital Gains Degrouping Rules – Part One
Mar 172013
 

This is the third article in our series on corporate tax groups where we explore the rules governing intra-group transactions, and how they are taxed. In this article we shall look at the rules relating to capital assets.

(This article is Part One of a two part mini-series on the Capital Gains Degrouping Rules. Both parts can be read in a single article in pdf format which can be downloaded at Academia.edu.)

Continue reading »