Commentary

D7.725 Compulsory liquidation of banks

Corporate tax
Corporate tax | Commentary

D7.725 Compulsory liquidation of banks

Corporate tax | Commentary

Special situations

D7.725 Compulsory liquidation of banks

A special relief against post-cessation receipts is available for expenses and losses incurred by banks etc in compulsory liquidation, which would have been allowable if the trade of the company had continued1. It is expressly stated that these provisions take precedence over the loan relationship rules2.

It is understood that the relief also applies to the winding-up of UK deposit taking permanent establishments of overseas companies3.

Companies eligible for relief

The relief applies to a company4 which5:

  1.  

    (a)     has been or is being wound-up by a UK court. A UK permanent establishment of an overseas company which is being wound-up by an overseas court would

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