D6.330 Special Situations Involving A Transfer Of Trade With Common Ownership—Business Of Leasing Plant Or Machinery

Home / Simons-Taxes / Corporate tax / Part D6 Company reconstruction and profit extraction / Division D6.3 Intra-group reorganisations / Transfer of a trade—75% common ownership / D6.330 Special situations involving a transfer of trade with common ownership—business of leasing plant or machinery

Commentary

Corporate tax

General rule for businesses which lease plant or machinery

Targeted anti-avoidance legislation applies to companies carrying on a business of leasing plant or machinery in relation to the CTA 2010, Pt 22 Ch 1 (ss 940A–953) provisions (ie the succession rules, see D6.315). 'Business of leasing plant or machinery' has the meaning given by CTA 2010, s 387.

For such companies the carry over of capital allowances under CTA 2010, Pt 22 Ch 1 (ss 940A–953) is not possible if the trade concerned is (or forms part of) a business of leasing plant or machinery which the predecessor or the successor carries out on the day of cessation. Instead, the plant or machinery belonging to the trade is treated as sold by the predecessor

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