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 section 768 of the 1988 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.