Capital Transfer Tax Act 1984

97 Transfers within group, etc.

(1) Where a close company (" the transferor company ") is a member, but not the principal member, of a group and—

(a) a disposal by the transferor company of any asset is a disposal to which section 273(1) of the Taxes Act applies and is also a transfer of value, and

(b) the transfer of value has only a small effect on the value of the minority participators' rights and interests in that company compared with its effect on the value of the other participators' rights and interests in the company,

the rights and interests of the minority participators shall be left out of account in determining the respective rights and interests of the transferor company's participators for the purpose of apportioning the value transferred under section 94 above.

(2) For the purposes of subsection (1) above—

(a) the principal member of a group is the member of which all the other members are 75 per cent. subsidiaries, and

(b) a minority participator is a participator of the transferor company who is not, and is not a person connected with, a participator of the principal member of the group or of any of the principal member's participators ;

and in this section " group " and " 75 per cent. subsidiary " have the same meanings as in section 272 of the Taxes Act.