Commentary

D8.122 Amalgamations and conversions

Corporate tax
Corporate tax | Commentary

D8.122 Amalgamations and conversions

Corporate tax | Commentary

D8.122 Amalgamations and conversions

The rules set out below apply in connection with a scheme of reorganisation where conditions A to E are met1.

Condition A is that the whole of the scheme property of an authorised unit trust that is available for transfer is transferred on a given date under an arrangement to an open-ended investment company2.

Condition B is that the consideration under the arrangement consists of or includes the issue, on the transfer date, of shares in the acquiring company to the holders of units in the target trust in exchange for those units3.

Condition C is that the consideration shares are issued to the holders of units in proportion to their holdings of the exchanged units4.

Condition D is that the consideration under the arrangement does not include anything else in addition to the issue of the consideration shares, other than (where applicable) the assumption or discharge by the acquiring company of liabilities of the trustees of the target trust5.

Condition E is that under the arrangement

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