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).