Commentary

D2.440 Overview

Corporate tax
Corporate tax | Commentary

D2.440 Overview

Corporate tax | Commentary

Other restrictions on pre-entry losses—Pooled assets

D2.440 Overview

The rules in this article were repealed in relation to the set off of pre-entry losses on or after 19 July 2011, subject to transitional rules (see D2.414).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

Pooled assets present a particular difficulty as regards the identification of pre-entry assets (see D2.417) and the calculation of the pre-entry proportion of the loss on disposal of

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