Commentary

D4.811 Transfer of a non-UK business

Corporate tax
Corporate tax | Commentary

D4.811 Transfer of a non-UK business

Corporate tax | Commentary

D4.811 Transfer of a non-UK business

The provisions in this article apply only to companies where an election has not been made for exemption for the profits of a foreign permanent establishment (D4.801). For details of the double tax relief provisions that generally apply equally to companies and individuals see Division E6.4.

The EC Mergers Directive1 took effect from 1 January 1992. It applies to the transfer of assets of a permanent establishment (PE) which a UK company has in another member state to a company resident in another member state in exchange for shares (or debentures) in that company. Where the directive applies, the country in which the PE is situated is not permitted to tax any capital gain

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