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Commentary

266.4 Anti-avoidance provisions and advance clearance

COMPANIES vol 11 acquisitions, mergers, demergers
| Commentary

266.4 Anti-avoidance provisions and advance clearance

| Commentary

266.4 Anti-avoidance provisions and advance clearance

Section 136 of the Taxation of Chargeable Gains Act 1992 will not apply to a scheme of reconstruction unless it is effected for bona fide commercial reasons, and does not form part of a scheme or arrangement of which the main purpose, or one of the main purposes, is avoidance of liability to capital gains tax or corporation tax1. This requirement does not apply to any person who does not own more than 5% of (or of any class of) the shares or debentures in the transferee company2.

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