Commentary

D4.127 Transferring a UK trade to a UK or EU resident company

Corporate tax
Corporate tax | Commentary

D4.127 Transferring a UK trade to a UK or EU resident company

Corporate tax | Commentary

D4.127 Transferring a UK trade to a UK or EU resident company

Transfer of a UK trade to a UK company

A non-resident company (company A) trading in the UK through a permanent establishment may wish to transfer the trade to a UK resident subsidiary company (company B). Without special provisions, such a transfer would usually involve a charge to corporation tax on chargeable gains as if the assets transferred had been disposed of for a consideration equal to market value.

Where such a transfer occurs, companies A and B are treated as if the trade were acquired by company

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