Revenue Precedents

Where a family trading company (or group of companies) is broken up into separate individual trading companies, such an event will not be regarded as a disposal for CGT purposes provided that the value of each individual's holding in the company or group remains strictly unaltered and also provided certain other conditions are met. Prior approval and formal undertakings will be required. Requests for this treatment should be addressed to the Technical Services (CGT) area in the office of the Chief Inspector of Taxes. G.12.