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Home / Simons-Taxes /Corporate tax /Part D8 Investment schemes /Division D8.1 Collective investment schemes /Authorised investment funds / D8.122 Amalgamations and conversions
Commentary

D8.122 Amalgamations and conversions

Corporate tax

The rules set out below apply in connection with a scheme of reorganisation where conditions A to E are met1.

Condition A is that the whole of the scheme property of an authorised unit trust that is available for transfer is transferred on a given date under an arrangement to an open-ended investment company2.

Condition B is that the consideration under the arrangement consists of or includes the issue, on the transfer date, of shares in the acquiring company to the holders of units in the target trust in exchange for those units3.

Condition C is that the consideration shares are issued to the holders of units in proportion to their holdings of the exchanged units4.

Condition D is that the consideration under the arrangement does not include anything else in addition to the issue of the consideration shares, other than (where applicable) the assumption or

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