Commentary

D2.413 Relevant group—Change of group as a result of a no gain/no loss disposal

Corporate tax
Corporate tax | Commentary

D2.413 Relevant group—Change of group as a result of a no gain/no loss disposal

Corporate tax | Commentary

D2.413 Relevant group—Change of group as a result of a no gain/no loss disposal

The rules in this article apply only where the loss buying rules (D2.402–D2.406) do not apply. As a result, for accounting periods ending after 4 December 2005, the following provisions will normally only apply in cases where there is no arrangement for avoiding tax, eg on a merger or takeover.

Where a company which is a member of a group of companies becomes a member of another group, the first group and the second group are treated as the same group of companies if the:

  1.  

    •     change

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