Section 139 of the Taxation of Chargeable Gains Act 1992 provides relief from the immediate payment of tax in most cases of company reconstruction. Where certain conditions are satisfied, the transfer of a business in the context of a scheme of reconstruction will be treated for corporation tax purposes as if any assets included in the transfer were acquired by the transferee company from the transferor company for such a consideration as will result in neither a gain nor a loss for the disposing company. The general conditions which must be satisfied for this relief to be
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