Commentary

D6.521 Transfer of UK trade to a company resident in the UK

Corporate tax
Corporate tax | Commentary

D6.521 Transfer of UK trade to a company resident in the UK

Corporate tax | Commentary

D6.521 Transfer of UK trade to a company resident in the UK

A non-resident company (company A) trading in the UK through a permanent establishment may wish to transfer the trade to a UK resident subsidiary company (company B). Without special provisions, such a transfer would usually involve a charge to corporation tax on chargeable gains as if the assets transferred had been disposed of for a consideration equal to market value1.

Transfer of UK PE to UK company—relieving provisions

Where such a transfer occurs, companies A and B are treated as if the assets were acquired by company B for

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