Commentary

D7.453 Transfers of assets between categories

Corporate tax
Corporate tax | Commentary

D7.453 Transfers of assets between categories

Corporate tax | Commentary

D7.453 Transfers of assets between categories

The tax rules act to separate a company's long-term business into categories which are treated as though they were separate businesses, with separate identification of income and capital gains, ring-fencing of expenses and taxation treatment generally. Companies legitimately transfer assets between these categories on a regular basis as part of their investment strategies and without further rules it might be possible to ensure that an asset pregnant with gain was transferred to a fund (for example one wholly matched to non-BLAGAB liabilities) in which the gain when realised would be exempt from tax. Conversely

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