[F1195BLicence-consideration swapU.K.
(1)This section applies to a licence-consideration swap.
(2)Each company participating in the swap is to be treated as follows.
(3)As regards the licence, or each licence, which the company disposes of, the company is to be treated as if it had disposed of that licence for a consideration of such amount as to secure that on the disposal neither a gain nor a loss accrues to the company.
(4)In a case where the company acquires only one licence, the company is to be treated as if it had acquired the licence for a consideration of the same amount as the deemed disposal consideration.
(5)In a case where the company acquires two or more licences, as regards each licence acquired, the company is to be treated as if it had acquired that licence for a consideration of—
where—
DDC is the deemed disposal consideration,
A is the value of the licence acquired, and
TA is total value of all the licences acquired.
(6)In this section “deemed disposal consideration”, in relation to a company participating in the swap, means—
(a)the amount of the consideration for which the company is, under subsection (3), treated as having disposed of its licence (if the company disposes of only one licence), or
(b)the aggregate of all such amounts (if the company disposes of two or more licences).]
Textual Amendments
F1Ss. 195A-195E inserted (with effect in accordance with Sch. 40 para. 8 of the amending Act) by Finance Act 2009 (c. 10), Sch. 40 para. 5