Part 1 Transfers to the NDA or a Subsidiary of the NDA

SCHEDULE 9 Taxation Provisions Relating to Nuclear Transfer Schemes

Section 47

Part 1 Transfers to the NDA or a Subsidiary of the NDA

Trading losses: transfer of company carrying on exempt activities

1

(1)     This paragraph applies for the purposes of corporation tax where—

(a)     in consequence of a section 39 scheme, a company which is not an NDA company becomes an NDA company falling within section 27(4)(a); and

(b)     the company carried on exempt activities before the coming into force of the scheme.

(2)     Trading losses attributable to the exempt activities carried on by the company before the coming into force of the scheme shall be treated, in relation to accounting periods beginning at or after that time, as extinguished.

(3)     For the purpose of determining the extent to which trading losses incurred by a company are attributable to exempt activities, such apportionments of receipts, expenses, assets and liabilities shall be made as may be just.

Trading losses: transfer of undertaking carrying on exempt activities

2

(1)     This paragraph applies for the purposes of corporation tax where—

(a)     a company (“the transferor companyâ€) which is not an NDA company is carrying on a trade which

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