Commentary

D2.407 Transitional provisions

Corporate tax
Corporate tax | Commentary

D2.407 Transitional provisions

Corporate tax | Commentary

D2.407 Transitional provisions

Under transitional provisions1, certain changes of ownership are ignored for the purpose of the restrictions on capital loss relief. This is generally where there is no economic change of ownership or where there is a loss occasioned by a degrouping charge.

These provisions apply, in relation to disposals of pre-change assets occurring on or after 21 March 2007 (with the exception of (c) below which has no effect in relation to disposals made before 9 May 2007), where2:

  1.  

    (a)     before 5 December 2005, there is a qualifying change of ownership of a company (A), for the purposes

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