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Legislation
Corporation Tax Act 2009

Crossheading Tax-neutral transfers

  • Section 818 Company reconstruction involving transfer of business
  • Section 819 European cross-border transfers of business: introduction
  • Section 820 Transfer of assets on European cross-border transfer of business
  • Section 821 European cross-border mergers: introduction
  • Section 822 Transfer of assets on European cross-border merger
  • Section 823 Interpretation of sections 821 and 822
  • Section 824 Transfer of business of building society to company
  • Section 825 Application of sections 780 and 785 where transfer within section 824 occurs
  • Section 826 Amalgamation of, or transfer of engagements by, certain societies
  1. Tax-neutral transfers
  2. Interpretation of sections 821 and 822

Section 823 | Interpretation of sections 821 and 822

From legislation.gov.uk

(1)This section applies for the interpretation of sections 821 and 822 and this section.

(1A)“Relevant state” means the United Kingdom or a member State.

(2)“Transferor” means—

(a)in relation to a merger within section 821(2)(a), a company merging to form the SE,

(b)in relation to a merger within section 821(2)(b), a co-operative society merging to form the SCE, and

(c)in relation to a merger within section 821(2)(c) or (d), each company transferring all its assets and liabilities.

(3)“Transferee” means—

(a)in relation to a merger within section 821(2)(a), the SE,

(b)in relation to a merger within section 821(2)(b), the SCE, and

(c)in relation to a merger within section 821(2)(c) or (d), the company to which assets and liabilities are transferred.

(4)“Transparent entity” has the meaning given in section 820(4).

(5)References to a company are references to any entity listed as a company in Part A of Annex I to the Mergers Directive.

(6)In section 821 and this section “co-operative society” means a society registered under the Co-operative and Community Benefit Societies Act 2014 or a similar society governed by the law of a member State ....

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