1(1)This paragraph applies where—U.K.
(a)there is a disposal of securities of a subsidiary of the original holding company to the Secretary of State or the Treasury (or a nominee of either of them) or to a company wholly owned by the Crown, and
(b)immediately before the disposal, the subsidiary was wholly owned by the original holding company.
(2)For the purposes of the Taxation of Chargeable Gains Act 1992 the disposal is to be treated in relation to—
(a)the person making the disposal, and
(b)the person to whom the disposal is made,
as made for a consideration such that no gain or loss accrues to the person making the disposal.
(3)The degrouping provisions are not to apply by reason of the disposal or any agreement to make the disposal (if they otherwise would).
(4)In this Schedule a “degrouping provision” means—
(a)section 179 of the Taxation of Chargeable Gains Act 1992 (company ceasing to be member of group), or
(b)paragraph 3 of Schedule 7 to the Finance Act 2003 (withdrawal of SDLT group relief).
(5)Stamp duty is not chargeable on the instrument effecting the disposal.
(6)This paragraph applies whether or not the disposal is made by or under a transfer scheme under section 8.
Commencement Information
I1Sch. 2 para. 1 in force at 1.10.2011 by S.I. 2011/2329, art. 3