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Home / Simons-Taxes /Corporate tax /Part D6 Company reconstruction and profit extraction /Division D6.5 International reorganisations /International movement of capital / D6.502A International movement of capital—excluded transactions
Commentary

D6.502A International movement of capital—excluded transactions


Corporate tax

A transaction is specifically excluded from the international movement of capital provisions (see D6.502) if1:

  1. Ìý

    (a)ÌýÌýÌýÌý it is carried out in the ordinary course of a trade

  2. Ìý

    (b)ÌýÌýÌýÌý all the parties to the transaction are resident in the same territory (at the time the transaction takes place)

  3. Ìý

    (c)ÌýÌýÌýÌý the transaction consists of the giving of security:

    1. Ìý

      (1)ÌýÌýÌýÌý to the bankers of a foreign subsidiary for any payment due from the subsidiary to the bankers by reason of any transaction entered into in the ordinary course of the bankers business, or

    2. Ìý

      (2)ÌýÌýÌýÌý by a foreign subsidiary to an insurance company for any payment due from the subsidiary to the insurance company by reason of any transaction

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