Commentary

D6.512 Cross-border exchanges between the UK and an EU country

Corporate tax
Corporate tax | Commentary

D6.512 Cross-border exchanges between the UK and an EU country

Corporate tax | Commentary

Exchange of securities

D6.512 Cross-border exchanges between the UK and an EU country

EU Council Directive 2009/133/EC (formerly 90/434/EEC), also referred to as the EU Tax Merger Directive, introduced measures to provide tax relief for shareholders receiving securities in a company belonging to an EU member state as a result of a qualifying exchange etc involving companies in two or more member states.

As the provisions of TCGA 1992, s 135 did not restrict relief by reference to the country of incorporation or the residence of the acquiring company, only minor amendments to that section were necessary to comply with

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