Separate anti-avoidance provisions apply1 on a change of ownership of a company with investment business where, after the change, there is an intra-group transfer to the company of an asset and either2:
- Ìý
•ÌýÌýÌýÌý where the change of ownership took place on or after 1 April 2017, that asset is sold outside the group within five years of the change of ownership of the company (three years if the change of ownership is before 1 April 2017); or
- Ìý
•ÌýÌýÌýÌý where the change of ownership took place on or after 1 April 2017, a chargeable gain is treated as accruing to the company by reason of an election to allocate the gain to it3
These provisions do not apply where there has been a major change in the nature, conduct or size of the company's investment business or a significant increase in the company's capital, because any avoidance of a chargeable gain in such circumstances will be countered by the provisions described in D7.3204.
The principle
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Web page updated on 17 Mar 2025 16:16