Commentary

D2.418 Pre-entry asset—Assets derived from other assets

Corporate tax
Corporate tax | Commentary

D2.418 Pre-entry asset—Assets derived from other assets

Corporate tax | Commentary

D2.418 Pre-entry asset—Assets derived from other assets

The rules in this article were repealed in relation to the set off of pre-entry losses on or after 19 July 2011, subject to transitional rules (see D2.414). Prior to 19 July 2011, the rules in this article applied only where the loss buying rules (D2.402–D2.406) did not apply (ie where there was no arrangement for avoiding tax, eg on a merger or takeover).

An asset (the second asset) is treated as the same as the first asset if the value of the second asset is derived in whole or in part from the

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