SCHEDULES
SCHEDULE 7 Transfer schemes: tax
Trading losses: change in ownership
I114
1
This paragraph applies if under a relevant transfer all the issued share capital of a company (the transferred company) is transferred from the CAA to—
a
the Secretary of State, or
b
a company whose shares are all held by the Secretary of State when the transfer takes effect.
2
For the purposes of F1Chapter 2 of Part 14 of the Corporation Tax Act 2010 (but not section 674(1) of that Act) (disallowance of trading losses on change in company’s ownership) the transfer is not to be taken to result in a change in the ownership of—
a
the transferred company, or
b
a company which is a wholly owned subsidiary of the transferred company when the transfer takes effect.