Commentary

D2.416 Pre-entry loss—Transfer of assets from the public sector

Corporate tax
Corporate tax | Commentary

D2.416 Pre-entry loss—Transfer of assets from the public sector

Corporate tax | Commentary

D2.416 Pre-entry loss—Transfer of assets from the public sector

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.

Certain capital losses, which would otherwise be pre-entry losses, are not to be treated as pre-entry losses on a privatisation or other public sector restructuring.

These provisions apply in specified situations concerning broadly the transfer of the assets and liabilities of a company owned by the Crown, or a body carrying on activities

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