Commentary

D2.404 Pre-change assets—Definition

Corporate tax
Corporate tax | Commentary

D2.404 Pre-change assets—Definition

Corporate tax | Commentary

D2.404 Pre-change assets—Definition

A pre-change asset means an asset held by the relevant company before the relevant time1, (the relevant time being the time when there is a qualifying change of ownership2).

This is extended to include:

  1.  

    •     a new asset whose value derives in whole or in part from a pre-change asset and is held by any company (A) at or after a change of ownership (unless it was acquired by A under a transaction other than an intra-group transaction3). The value of an asset may derive from another asset where assets have been merged, divided or have changed their

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