Commentary

D6.325 Transfer of a trade where 75% common ownership—overview of qualifying conditions

Corporate tax
Corporate tax | Commentary

D6.325 Transfer of a trade where 75% common ownership—overview of qualifying conditions

Corporate tax | Commentary

D6.325 Transfer of a trade where 75% common ownership—overview of qualifying conditions

When a trade, or part of a trade, is transferred between companies in common ownership, special provisions apply (see D6.315–D6.318 for further details) in relation to capital allowances and trading losses.

Before those provisions can operate the following conditions must apply1:

  1.  

    (a)     a company, (the 'predecessor'), must cease to carry on a trade or part of a trade, and another company (the 'successor') must carry on that same trade or part of that trade as its trade or part of its trade (D6.326)

  2.  

    (b)     on the

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