Tax issues on the implementation of the Vickers report

It seems that implementation of the Vickers report will require a banking group to divide its investment banking and retail banking operations between ringfenced group entities.

Tax might seem to be a relatively unimportant item in the scale of things but I suspect that there may be a number of questions to consider both on implementation and in respect of continuing tax matters.

For instance transfers of capital assets between the relevant companies would be made on a no gain no loss basis: should the transferor indemnify the transferee for...