Commentary

D6.532 Merger to form SE/SCE etc—no assets left within UK tax charge

Corporate tax
Corporate tax | Commentary

D6.532 Merger to form SE/SCE etc—no assets left within UK tax charge

Corporate tax | Commentary

D6.532 Merger to form SE/SCE etc—no assets left within UK tax charge

Where the merger does not leave assets within the UK tax charge, a different relief applies1.

If the following conditions are met the allowable losses accruing to the transferor company (referred to a Company A) on the transfer (Y) are set off against the gains on the transfer (X), so that Company A is treated as making a single chargeable gain equal to X – Y2. Also, for double taxation relief purposes, similar relief to that described at D6.522 is available3. The tax which would have been payable if

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