Commentary

B9.111 Incorporation relief—overview

Business tax
Business tax | Commentary

B9.111 Incorporation relief—overview

Business tax | Commentary

B9.111 Incorporation relief—overview

Incorporation relief is available where the transfer of the unincorporated business to the company is wholly or partly in consideration for the issue of shares by the company to the transferor(s)1 and the other conditions in B9.112 are met. The chargeable gains are apportioned rateably between shares and other consideration received, in the ratio of the respective market values at the time of the transferor's acquisition of them. The part attributed to the shares is not assessed, but is deducted from (ie rolled over against) the allowable cost of acquisition of those shares. The remainder of the

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