Commentary

D2.445 General calculation—Election for market value calculation

Corporate tax
Corporate tax | Commentary

D2.445 General calculation—Election for market value calculation

Corporate tax | Commentary

D2.445 General calculation—Election for market value calculation

The rules in this article were repealed in relation to the set off of pre-entry losses on or after 19 July 2011, subject to transitional rules (see D2.414).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 market value rules1 that apply to non-pooled assets (D2.421), apply equally to pooled assets, but with additional provisions which:

  1.  

    •     set out a special method for calculating the loss which would have accrued on a disposal of the asset for market value at the time when the relevant event (D2.417) occurred in relation to the company concerned whilst it held the asset2, and

  2.  

    •     provide a special rule for calculating the pre-entry proportion on a subsequent disposal of a pooled asset3, where the pre-entry proportion has been calculated by reference to the special calculation method4 (see D2.446)

Special

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