Commentary

D2.415 Pre-entry loss—Appropriations to stock in trade

Corporate tax
Corporate tax | Commentary

D2.415 Pre-entry loss—Appropriations to stock in trade

Corporate tax | Commentary

D2.415 Pre-entry loss—Appropriations to stock in trade

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 capital asset is appropriated to trading stock there is a deemed disposal at market value1 and in the case of a company which joins a group of companies after such an appropriation any capital loss on the deemed disposal would, of course,

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