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Legislation
Corporation Tax Act 2009

Crossheading Transfer of assets to non-UK resident company

  • Section 827 Claims to postpone charge on transfer
  • Section 828 Relief on transfer
  • Section 829 Charge on subsequent realisations
  • Section 830 Exclusion from section 829 of group transfers
  1. Transfer of assets to non-UK resident company
  2. Relief on transfer

Section 828 | Relief on transfer

From legislation.gov.uk

(1)If the proceeds of realisation of a relevant asset exceed the cost of the asset recognised for tax purposes, the proceeds are treated as reduced.

(2)If the securities are the whole consideration for the transfer, the reduction is by the amount of the excess.

(3)If the securities are not the whole of that consideration, the reduction is by the appropriate proportion of the excess.

(4)In subsection (3) “the appropriate proportion” means the proportion that the market value of the securities at the time of the transfer bears to the market value of the whole of the consideration at that time.

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