Commentary

D2.419 Pre-entry asset—Qualifying corporate bonds

Corporate tax
Corporate tax | Commentary

D2.419 Pre-entry asset—Qualifying corporate bonds

Corporate tax | Commentary

D2.419 Pre-entry asset—Qualifying corporate bonds

The rules in this article were repealed in relation to the set off of pre-entry losses on or after 19 July 2011, subject to transitional rules (see D2.414).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).

A special provision1 applies if, after a company joins a relevant group (D2.411), qualifying corporate bonds2 (QCB's) are issued in exchange for other securities of a company as a result of a

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