“In order for companies to qualify for exemption from a taxable charge under s 179 of the Taxation of Chargeable Gains Act 1992, they had to be ‘associated’ not only at the time of leaving the group but also at the time of the relevant intra-group transfer. On the proper construction of the section, the use of the word ‘associated’ on its second appearance was not redundant but required the court to consider whether that word was intended to serve some purpose and was not redundant.”
WLR Daily, 24th July 2008
Source: www.lawreports.co.uk
Please note once a case has been fully reported in one of the ICLR series the corresponding WLR Daily summary is removed.
