Commentary

D6.315 Implications on a transfer of a trade where 75% common ownership—overview

Corporate tax
Corporate tax | Commentary

D6.315 Implications on a transfer of a trade where 75% common ownership—overview

Corporate tax | Commentary

Transfer of a trade—75% common ownership

D6.315 Implications on a transfer of a trade where 75% common ownership—overview

Where there is 75% common ownership (D6.327) between the predecessor and successor company, the rules detailed at D6.310 apply with the exception of those relating to capital allowances and trading losses on the transfer of a trade.

A transfer of a trade within 75% common ownership is sometimes referred to as a succession to a trade. Broadly, under the succession rules (which are compulsory; no election is necessary)1 the successor is effectively treated as if it were the predecessor company for

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