AB17: Changes to corporation tax on chargeable gains - KPMG United Kingdom
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Autumn Budget 2017: Changes to corporation tax on chargeable gains

AB17: Changes to corporation tax on chargeable gains

CT on chargeable gains: Indexation allowance frozen from 1 January 2018 and depreciatory transactions time limit abolished from 22 November 2017.


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Indexation allowance on corporate capital gains is to be frozen for disposals made on and after 1 January 2018. This will affect property disposals in particular, with the tax take from these increasing over time. It may also mean that gains on disposals of UK commercial property by non-resident companies - which are expected to become chargeable from April 2019 – will not attract indexation allowance.

A capital loss arising on a disposal of shares in a group company must be reduced for any depreciatory transactions that took place in the six years prior to disposal. For disposals made on or after 22 November 2017, the six year time limit is abolished. This is to prevent companies waiting until after the six year time limit has passed so that they can claim the loss that arose as a result of an earlier depreciatory transaction.


Iain Kerr

+44 (0)20 7311 5621


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