Taxes Consolidation Act 1997 Schedule 17 paragraph 5

Capital gains

Paragraph 5 sets out the capital gains tax treatment of assets transferred during a trustee savings bank reorganisation, ensuring that no chargeable gain or loss arises on the transfer itself while preserving the original acquisition history for future disposals.

• Assets transferred from a bank to its successor company in the course of a reorganisation are deemed to be disposed of for a consideration that produces neither a gain nor a loss.
• On any subsequent disposal by the successor company, the asset is treated as having been acquired at the time and cost at which it was originally acquired by the trustee savings bank (or, where applicable, by the bank controlled by the Minister for Finance).
• Any unused allowable capital losses of the bank are carried forward to the successor company and may be set against its future chargeable gains.
• A debt owed to the bank does not become a chargeable asset merely because it is transferred to the successor company as part of the reorganisation.