SCHEDULES

SCHEDULE 13Transfer schemes: tax provisions

Part 5Other provisions concerning transfers between public bodies

Trading losses: change in ownership

30

(1)

This paragraph applies to a relevant transfer of all the issued share capital of a company (the “transferred company”).

(2)

For the purposes of sections 768 to 768E of ICTA, 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.