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 purposes) in respect of an intra-group acquisition of an asset within the previous 6 years. For capital gains purposes, intra-group transfers of assets are deemed to occur at a no gain/no loss price; consequently, the...