SCHEDULES

SCHEDULE 5Avoidance involving financial arrangements

Options and groups of companies

10

1

In section 171(2) of TCGA 1992 (exceptions to rule that disposals within the same group of companies produce neither a gain nor a loss), after paragraph (da) insert

or

db

a disposal by company A in fulfilment of its obligations under an option granted to company B at a time when those companies were not members of the same group;

2

The amendment made by sub-paragraph (1) has effect in relation to cases where the option is exercised on or after 6th March 2007 (whenever the option was granted).