Section 210 | Transfer of assets or liabilities from a member of a multinational group

(1)Where a member of a multinational group transfers assets or liabilities to another entity in the course of a qualifying reorganisation (see section 212), any gain or loss on the transfer is to be excluded from the adjusted profits of the member, except to the extent it is a non-qualifying gain or loss.

(2)In this section, and in sections 211 and 212, “non-qualifying gain or loss” means a gain or loss of the transferor on the transfer of assets or liabilities, and is the lesser of—^F1

(a)the amount of that gain or loss that is subject to tax in the territory the transferor is located in, and^F1

(b)the amount of that gain or loss reflected in the underlying profits accounts of the transferor.^F1