Section 676ED | Indirect transfers of a trade ^F1

(1)Subsections (2) and (3) apply if a trade transferred by the transferred company or a co-transferred company is transferred on a subsequent occasion to another company.

(2)The transferred company or (as the case may be) the co-transferred company is to be treated for the purposes of this Chapter—

(a)as having transferred the trade to that other company, and

(b)as having done so at the time it was actually transferred to that other company.

(3)The deemed transfer is to be treated for the purposes of this Chapter as a transfer to which Chapter 1 of Part 22 applies if the actual transfer to the other company was a transfer to which that Chapter applies.

(4)Subsections (5) and (6) apply if—

(a)a trade (“the original trade”) is transferred by the transferred company or a co-transferred company,

(b)the activities of the original trade are included in the activities of another trade (“the composite trade”), and

(c)the composite trade is transferred to another company.

(5)The transferred company or (as the case may be) the co-transferred company is to be treated for the purposes of this Chapter—

(a)as having transferred the original trade to that other company, and

(b)as having done so at the time the composite trade was actually transferred to that other company.

(6)The deemed transfer is to be treated for the purposes of this Chapter as a transfer to which Chapter 1 of Part 22 applies if the transfer of the composite trade to the other company was a transfer to which that Chapter applies.