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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. Exclusion from section 829 of group transfers

Section 830 | Exclusion from section 829 of group transfers

From legislation.gov.uk

(1)For the purposes of section 829(1), any disposal within section 171 of TCGA 1992 (transfers within a group) is ignored.

(2)For the purposes of section 829(3), any transfer by one member of a group to another is ignored.

(3)This subsection applies if—

(a)a person (“A”) acquires securities on a transfer that is ignored under subsection (1), and

(b)any previous transfer that has occurred was ignored under subsection (1) or (2).

(4)If subsection (3) applies, a subsequent realisation of the securities by A is treated as a realisation by the transferor.

(5)This subsection applies if—

(a)a person (“B”) acquires an asset on a transfer that is ignored under subsection (2), and

(b)no previous transfer has occurred that was not ignored under subsection (1) or (2).

(6)If subsection (5) applies, a subsequent realisation of the asset by B is treated as a realisation by the transferee.

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