{
  "url": "https://openlegislation.uk/taxation-of-chargeable-gains-act-1992/section-192",
  "json_url": "https://openlegislation.uk/taxation-of-chargeable-gains-act-1992/section-192.json",
  "legislation": "ukpga/1992/12",
  "legislation_title": "Taxation of Chargeable Gains Act 1992",
  "legislation_url": "https://openlegislation.uk/taxation-of-chargeable-gains-act-1992",
  "path": "section/192",
  "kind": "section",
  "number": "192",
  "heading": "Tax exempt distributions.",
  "text": "(1) This section has effect for facilitating certain transactions whereby trading activities carried on by a single company or group are divided so as to be carried on by 2 or more companies not belonging to the same group or by 2 or more independent groups.\n(2) Where a company makes a distribution which is exempt by virtue of section 1076 of CTA 2010—\n(a) the distribution shall not be a capital distribution for the purposes of section 122; and\n(b) sections 126 to 130 shall, with the necessary modifications, apply as if that company and the subsidiary whose shares are transferred were the same company and the distribution were a reorganisation of its share capital.\n(3) Subject to subsection (4) below, section 179 shall not apply in a case where a company ceases to be a member of a group by reason only of an exempt distribution.\n(4) Subsection (3) does not apply if within 5 years after the making of the exempt distribution there is chargeable payment; and the time for making an assessment under section ... 179 by virtue of this subsection shall not expire before the end of 3 years after the making of the chargeable payment.\n(5) In this section—\n“chargeable payment” has the meaning given in section 1088 of CTA 2010;\n“exempt distribution” means a distribution which is exempt by virtue of section 1076 or 1077 of CTA 2010; and\n“group” means a company which has one or more 75 per cent. subsidiaries together with that or those subsidiaries.\n(6) In determining for the purposes of this section whether one company is a 75 per cent. subsidiary of another, the other company shall be treated as not being the owner of—\n(a) any share capital which it owns directly in a body corporate if a profit on a sale of the shares would be treated as a trading receipt of its trade; or\n(b) any share capital which it owns indirectly and which is owned directly by a body corporate for which a profit on the sale of the shares would be a trading receipt.",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "Words in s. 192(2) substituted (with effect in accordance with s. 1184(1) of the amending Act) by Corporation Tax Act 2010 (c. 4), s. 1184(1), Sch. 1 para. 247(2) (with Sch. 2)"
    },
    {
      "type": "F",
      "label": "F2",
      "text": "Words in s. 192(3) substituted (28.7.2000) by Finance Act 2000 (c. 17), Sch. 29 para. 29 (with Sch. 29 para. 46(5))"
    },
    {
      "type": "F",
      "label": "F3",
      "text": "Words in s. 192(4) repealed (28.7.2000) by Finance Act 2000 (c. 17), Sch. 40 Pt. II(12)"
    },
    {
      "type": "F",
      "label": "F4",
      "text": "Words in s. 192(5) substituted (with effect in accordance with s. 1184(1) of the amending Act) by Corporation Tax Act 2010 (c. 4), s. 1184(1), Sch. 1 para. 247(3)(a) (with Sch. 2)"
    },
    {
      "type": "F",
      "label": "F5",
      "text": "Words in s. 192(5) substituted (with effect in accordance with s. 1184(1) of the amending Act) by Corporation Tax Act 2010 (c. 4), s. 1184(1), Sch. 1 para. 247(3)(b) (with Sch. 2)"
    },
    {
      "type": "C",
      "label": "C1",
      "text": "Ss. 170-192 restricted (27.7.1999) by Commonwealth Development Corporation Act 1999 (c. 20), Sch. 3 paras. 1, 4(1)"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/1992/12/section/192",
    "retrieved_at": "2026-10-29T09:36:15.270072+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}