Commentary

D9.115 The prescribed circumstances—Circumstance E

Corporate tax
Corporate tax | Commentary

D9.115 The prescribed circumstances—Circumstance E

Corporate tax | Commentary

D9.115 The prescribed circumstances—Circumstance E

These provisions apply for corporation tax purposes. For details of the income tax regime see D9.116A–D9.119.

Circumstance E1 applies where a person receives non-taxable consideration:

  1.  

    (a)     which consists of any share capital or security issued by a relevant company2; and

  2.  

    (b)     which is or represents the value of assets which:

    1.  

      (1)     are available for distribution by way of dividend by a relevant company;

    2.  

      (2)     would have been so available but for anything done by the company, or

    3.  

      (3)     are trading stock of the relevant company;

  3.  

    (c)     in connection with the transfer directly or indirectly of assets

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