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Home / Simons-Taxes /Corporate tax /Part D4 Overseas issues /Division D4.1 Non-resident companies /Taxation of non-resident companies / D4.127 Non-resident companies—transferring a UK trade to a UK or EU resident company

D4.127 Non-resident companies—transferring a UK trade to a UK or EU resident company

Corporate tax

Transfer of a UK trade to a UK company

A non-resident company (company A) trading in the UK through a permanent establishment may wish to transfer the trade to a UK resident subsidiary company (company B). Without special provisions, such a transfer would usually involve a charge to corporation tax on chargeable gains as if the assets

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E4.507S Operation of the charge on securities with artificially enhanced market value

I7.333A Companies and replacement APR property

C1.106 Allowable capital losses

A4.204 Claims procedure—corporation tax

I7.323 APR and successions

I4.142A Liabilities which are not discharged out of the estate

C3.1814A CGT exempt assets—qualifying corporate bonds (QCB)

A1.810 Limitation

E8.271 Liability for Class 1A contributions

B2.315 The concept of wholly and exclusively

D6.618 Capital treatment on a purchase of own shares—HMRC advance clearance and reporting obligations

I7.120A BPR and excepted assets

C1.511 Use of Mansworth v Jelley losses

I11.215 IHT accounts—excepted settlements

I5.1212 Protector of a foreign trust

C2.106 Deferred and contingent consideration on disposals

D6.233 Rights issue—sale of rights nil paid

D4.104 Company residence and the case law test

D4.412 CFCs—excluded territories exemption

D1.1422 Calculating NGIE and ANGIE