212 Meaning of “qualifying reorganisation”

212  Meaning of “qualifying reorganisation”

(1)     For the purposes of sections 210 and 211, a transfer of assets or liabilities is made in the course of a qualifying reorganisation if the transfer takes place as a result of a merger, de-merger, liquidation or a change in form of an entity, or a similar event, and conditions A, B and C are met.

(2)     Condition A is that—

(a)     any consideration for the transfer is, or the transfer involves, wholly or mostly equity interests issued by the transferee, or by a person connected with the transferee,

(b)     in the case of a liquidation, any consideration for the transfer is, or

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