Commentary

D2.422 Pre-entry proportion—Shares etc received on a reorganisation

Corporate tax
Corporate tax | Commentary

D2.422 Pre-entry proportion—Shares etc received on a reorganisation

Corporate tax | Commentary

D2.422 Pre-entry proportion—Shares etc received on a reorganisation

The rules in this article were repealed in relation to the set off of pre-entry losses on or after 19 July 2011, subject to transitional rules (see D2.414).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

The calculation of the pre-entry proportion of a loss is modified where shares or debentures are received (the new holding) under a reorganisation (or a transaction dealt with in

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