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Contents

Official guidance
Company Taxation Manual

CTM06300 · Corporation Tax: loss-buying

  • CTM06305 · Introduction
  • CTM06310 · Identifying cases
  • CTM06320 · Advising taxpayers
  • CTM06340 · Change in ownership
  • CTM06350 · Groups of companies
  • CTM06355 · Change in ultimate parent
  • CTM06370 · Major change in nature or conduct of a trade
  • CTM06380 · SP10/91
  • CTM06390 · Trading activities becoming small or negligible
  • CTM06400 · Company reconstructions
  • CTM06420 · Accounting period in which change of ownership occurs
  • CTM06430 · Capital allowances
  • CTM06450 · Profit-buying
  1. Corporation Tax: loss-buying: contents
  2. Corporation Tax: loss-buying: SP10/91

CTM06380 | Corporation Tax: loss-buying: SP10/91

From HM Revenue & Customs · Company Taxation Manual

SP10/91, a revised version of which was issued on 22 April 1996, explains the basis on which HMRC interprets ‘a major change in the nature or conduct of a trade’ (or, as appropriate, ‘business’) for various purposes, including CTA10/S673.

If a company or agent asks for clarification of SP10/91, the guidance at CTM06320 should be followed. In particular, officers should make sure they are not, in effect, being asked to advise on the structuring of a proposed transaction.

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)

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