If a Subsidiary transfers all of its Business to another member of the Tax Group, the Subsidiary shall be considered to leave the Tax Group on the date it transfer its entire business to other members and ceases to exist.
However, if the Tax Group only comprises two members and one member transfers its entire business to the other member, the first member ceases to exist as a result of that transfer. In such case the Tax Group shall be considered to cease to exist on the date that the transfer is effective.
Any gain or loss on the assets and liabilities transferred as part of the transfer of the Business may be taken into account while determining the Taxable Income of the Tax Group except if such a gain or loss would not have been taken into account had the Subsidiary elected for Business Restructuring Relief or Qualifying Group Relief.