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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 / D6.325 Transfer of a trade where 75% common ownership—qualifying conditions
Commentary

D6.325 Transfer of a trade where 75% common ownership—qualifying conditions


Corporate tax

When a trade, or part of a trade, is transferred between companies in common ownership, special provisions apply (see D6.315–D6.318 for further details) in relation to capital allowances and trading losses.

Before those provisions can operate the following conditions must apply1:

  1. Ìý

    (a)ÌýÌýÌýÌý a company, (the 'predecessor'), must cease to carry on a trade or part of a trade, and another company (the 'successor') must carry on that same trade or part of that trade as its trade or part of its trade (D6.326)

  2. Ìý

    (b)ÌýÌýÌýÌý on the transfer (or at any time within two years

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