Commentary

D7.5161 Taxing the transferor – Non long-term fund transferred assets

Corporate tax
Corporate tax | Commentary

D7.5161 Taxing the transferor – Non long-term fund transferred assets

Corporate tax | Commentary

D7.5161 Taxing the transferor – Non long-term fund transferred assets

The rules in this division apply for accounting periods beginning before 1 January 2013. For accounting periods beginning on or after 1 January 2013 see Division D7.4.

In essence, the purpose of the non-long term fund transferred assets provision (relevant non-transferred assets for transfers of business taking place before 22 June 2010) is to prevent the use of the book value election in INPRU(INS) 9.10(c) to transfer assets standing in the transferor's books at less than fair value (usually, but not necessarily, admissible value) to a transferee where, because it

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