Commentary

D2.448 Special calculation—Assumed order of disposal

Corporate tax
Corporate tax | Commentary

D2.448 Special calculation—Assumed order of disposal

Corporate tax | Commentary

D2.448 Special calculation—Assumed order of disposal

The rules in this article were repealed in relation to the set off of pre-entry losses on or after 19 July 2011, subject to transitional rules (see D2.414).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

For the purposes of identifying the assets which are to be treated as being comprised in the post-entry element, the company is deemed to dispose of assets

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