Page 22 - P6 Slide Taxation - Lecture Day 6 - Groups, Interest And Practice Questions

Intra-group transactions

• The transferor and transferee company must form part

of the same group of companies. The company

acquiring the asset must be a resident company.

• If the transferor held the asset as trading stock, the

transferee must hold the asset as trading stock.

• Vice versa, if the transferor held the asset as a capital

asset, the transferee must hold the asset as a capital

asset.

• NB! If an asset-for-share transaction takes place within

a group of companies, section 42 will be applicable and

not section 45.

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