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Home / Simons-Taxes /Corporate tax /Part D6 Company reconstruction and profit extraction /Division D6.5 International reorganisations /Takeovers and mergers—international aspects / D6.521 Transfer of UK trade to a company resident in the UK

D6.521 Transfer of UK trade to a company resident in the UK

Corporate tax

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 transferred had been disposed of for a consideration equal to market value¹.

Transfer of UK PE to UK company—relieving provisions

Where

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I4.265 Lifetime transfers reported late

B3.340A Hire purchase of plant and machinery and similar contracts

I3.367 Fall in value relief—changes in interests in land

I3.750 POAT—introduction to existing arrangements

B5.123 BPS—negligible value claims

C1.106A Annual exempt amount

A4.557 Late filing penalties—company tax returns

B5.820 Charity's profits of trade—general liability to income tax

C2.201 Allowable expenditure for capital gains—overview

C2.1231 Leases—deemed premiums

I8.335 Valuation on death of partner in service

I7.120A BPR and excepted assets

E4.115 Employment income—place of performance of duties

B3.1006 The relevant interest

B5.846 Charities and close companies

I5.1122 More than one settlor (income tax and CGT)

D6.711 Liquidation—capital gains implications

C2.1173 Interaction of the exemption election regime with other capital gains exemptions

D6.330 Special situations involving a transfer of trade with common ownership—business of leasing plant or machinery

D4.104 Company residence and the case law test