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Home / Simons-Taxes /Corporate tax /Part D6 Company reconstruction and profit extraction /Division D6.3 Intra-group reorganisations /Transfer of a trade—75% common ownership / D6.315 Implications on a transfer of a trade where 75% common ownership—overview
Commentary

D6.315 Implications on a transfer of a trade where 75% common ownership—overview

Corporate tax

D6.315 Implications on a transfer of a trade where 75% common ownership—overview

Where there is 75% common ownership (D6.327) between the predecessor and successor company, the rules detailed at D6.310 apply with the exception of those relating to capital allowances and trading losses on the transfer of a trade.

A transfer of a trade within 75% common ownership is sometimes referred

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