Where the merger does not leave assets within the UK tax charge, a different relief applies1.
If the following conditions are met the allowable losses accruing to the transferor company (referred to a Company A) on the transfer (Y) are set off against the gains on the transfer (X), so that Company A is treated as making a single chargeable gain equal to X – Y2. Also, for double taxation relief purposes, similar relief to that described at D6.522 is available3. The tax which would have been payable if the Mergers Directive had not applied is treated as tax paid
To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to Tolley+™ Research or register for a free trial
Web page updated on 17 Mar 2025 17:44