Paragraph 12

In section 171 (transfers within a group: general provisions), in subsection (2), after paragraph (b) insert—

“(ba)

a relevant high value disposal on which (ignoring subsection (1)) there accrues to company A an ATED-related gain chargeable to, or an ATED-related loss allowable for the purposes of, capital gains tax by virtue of section 2B; or”.