Changing horses: Key features of the incorporation and disincorporation reliefs in TCGA 1992

Capital gains tax incorporation relief, “rollover relief on transfer of business”, has been around for a long time. In contrast, disincorporation relief was enacted only last year, when the government estimated that around 610,000 companies, about 40% of those in the UK, would be eligible for relief against corporation tax on chargeable gains.

In each case, the policy rationale is that tax charges should not act as a barrier to proposed changes in the structure of a business.

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