Commentary

D7.5181 Conditions for relief

Corporate tax
Corporate tax | Commentary

D7.5181 Conditions for relief

Corporate tax | Commentary

D7.5181 Conditions for relief

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.

For periods of account beginning before 1 January 2007, the reliefs described above were subject to the overall condition that the transfer in question must have been carried out for bona fide commercial reasons, and must not have formed part of a scheme or arrangement of which the main purpose, or one of the main purposes, was the avoidance of liability to corporation tax1. The company to which the

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