Commentary

D2.430 Relief for pre-entry loss—Assets disposed of outside the group

Corporate tax
Corporate tax | Commentary

D2.430 Relief for pre-entry loss—Assets disposed of outside the group

Corporate tax | Commentary

D2.430 Relief for pre-entry loss—Assets disposed of outside the group

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.

An asset giving rise to a gain is not to be treated as a pre-entry asset (and cannot therefore be set against any pre-entry losses) if1:

  1.  

    •     the disposal giving rise to the gain is not made by the company which

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