| Commentary

163 Group reconstruction relief

| Commentary

163 Group reconstruction relief

Group reconstruction relief applies to transfers of assets within a group of companies consisting of a holding company and all its wholly-owned subsidiaries. It covers the situation where the issuing company is a wholly-owned subsidiary of another company and issues shares either to that other company or to another wholly-owned subsidiary of the holding company, in return for non-cash assets belonging to another company in the group (not necessarily the one to which the shares are issued)1. Where the shares in the issuing company are allotted at a premium, the issuing company need not transfer to

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