Transfers within groups
Special rules apply to achieve tax-neutrality in relation to intra-group transfers1. These rules apply when:
- Ìý
(a)ÌýÌýÌýÌý a company (A) which is a party to a derivative contract is replaced directly or indirectly by another company (B), where the two companies are members of the same group and are within the charge to corporation tax2. For this purpose a group is a parent company and its 75% subsidiaries3
- Ìý
(b)ÌýÌýÌýÌý the replacement occurs as a result of a series of transactions which have the same effect as a related transaction between A and B where each of A and B was a member of the same group at any time in the course of the series of transactions4
- Ìý
(c)ÌýÌýÌýÌý B becomes
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Web page updated on 24 Aug 2024 12:25