Commentary

D7.827 Methods of effecting mergers

Corporate tax
Corporate tax | Commentary

D7.827 Methods of effecting mergers

Corporate tax | Commentary

Mergers/transfers of building societies

D7.827 Methods of effecting mergers

Background

There are long-standing tax reliefs available to cover transfers of a trade between companies, often including anti-avoidance provisions. These are wide ranging and include, for instance, transfer of trading losses and continuity of capital allowances. They will usually be unavailable to mutual bodies (ie building societies, registered societies (formerly industrial and provident societies), or friendly societies) because the latter may not fall within the necessary definition of a company and because a degree of common ownership may be required between transferor and transferee.

A private member bill introduced the Building

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