On 14 March 2007, the High Court gave judgment in the case of Johnston Publishing (North) Ltd. v. HMRC [2007] EWHC 512 (Ch) concerning the scope of the capital gains degrouping charge under Sec. 179 Taxation of Chargeable Gains Act 1992 (TCGA).

Sec. 179 of the TCGA deems a capital gain to arise in a company that leaves a group (as defined for capital gains purpose…

Continue Reading