Commentary

D6.461 Company purchase scheme—conditions

Corporate tax
Corporate tax | Commentary

D6.461 Company purchase scheme—conditions

Corporate tax | Commentary

D6.461 Company purchase scheme—conditions

The provisions apply where there is a change in the ownership of a company and corporation tax remains unpaid six months after the change in ownership. The exact conditions vary depending upon whether the assessment is in relation to an accounting period beginning before the change in ownership1 or one ending on or after the change in ownership2.

For both scenarios an assessment may be raised to recover the unpaid tax in the name of the company albeit that it is issued to any:

  1.  

    (a)     person who controlled the company with the tax debt during the relevant period; or

  2.  

    (b)     company which that person controlled at any time during the three years before the change in ownership of the company (See D6.462).

Meaning of change of ownership of a company

A

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