Commentary

D9.301B Qualifying conditions

Corporate tax
Corporate tax | Commentary

D9.301B Qualifying conditions

Corporate tax | Commentary

D9.301B Qualifying conditions

The provisions detailed in D9.301A only apply where1:

  1.  

    (a)     a company ('the transferor') makes a transfer to a person ('the transferee') of a right to 'relevant receipts'. Relevant receipts are defined as any income that but for the transfer would be charged to corporation tax as income of the transferor or brought into account in calculating profits of the transferor for the purposes of corporation tax. The reason for referring to income that is brought into account in calculating profits is to ensure that the sale of a right to income which would be a component in

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