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Legislation
Corporation Tax Act 2010

CHAPTER 2E Post-1 April 2017 trade losses: cases involving the transfer of a trade

  • Section 676EA Introduction to Chapter
  • Section 676EB Restriction on use of trade losses carried-forward on transfer of trade
  • Section 676EC Restriction on surrender of trade losses carried forward on transfer of trade
  • Section 676ED Indirect transfers of a trade
  • Section 676EE Interpretation of Chapter
  1. Chapter 2E
  2. Interpretation of Chapter

Section 676EE | Interpretation of Chapter

From legislation.gov.uk

(1)Section 940B (meaning of “transfer of trade” and related expressions) applies for the purposes of this Chapter as it applies for the purposes of Chapter 1 of Part 22.

(2)In this Chapter “co-transferred company” means any company which is related to the transferred company both immediately before and immediately after the change in ownership.

(3)For the purposes of this Chapter any two companies (“T”) and (“C”) are “related” to one another at any time when—

(a)the group condition is met in relation to T and C, or

(b)any of consortium conditions 1 to 4 is met in relation to T and C,

(whether on the assumption that T is the claimant company and C is the surrendering company or vice versa).

(4)In this Chapter—

“consortium condition 1” is to be interpreted in accordance with section 188CF,

“consortium condition 2” is to be interpreted in accordance with section 188CG,

“consortium condition 3” is to be interpreted in accordance with section 188CH,

“consortium condition 4” is to be interpreted in accordance with section 188CI,

“the group condition” is to be interpreted in accordance with section 188CE.”

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