The following Tax precedent Produced in partnership with Anne Fairpo of Temple Tax Chambers provides comprehensive and up to date legal information covering:
[Addressed to HMRC Inspector]
We hereby jointly elect pursuant to section 792 of the Corporation Tax Act 2009 (CTA 2009) for [the whole OR [insert a specific amount, a percentage or a fraction]] of the chargeable realisation gain accruing on the deemed realisation and reacquisition of the intangible assets to be treated as accruing to [full company name] (Company B) rather than [full company name] (Company A).
For the purpose of this notice:
deemed realisation and reacquisition
means the deemed realisation and reacquisition of the intangible assets pursuant to section [780 OR 785] of CTA 2009 in consequence of [insert details of event leading to Company A leaving the group, eg sale of shares pursuant to a share purchase
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