Part 8Intangible fixed assets

Chapter 11Transfer of business or trade

Tax-neutral transfers

823Interpretation of sections 821 and 822

(1)

This section applies for the interpretation of sections 821 and 822 and this section.

(2)

“Transferor” means—

(a)

in relation to a merger within section 821(2)(a), a company merging to form the SE,

(b)

in relation to a merger within section 821(2)(b), a co-operative society merging to form the SCE, and

(c)

in relation to a merger within section 821(2)(c) or (d), each company transferring all its assets and liabilities.

(3)

“Transferee” means—

(a)

in relation to a merger within section 821(2)(a), the SE,

(b)

in relation to a merger within section 821(2)(b), the SCE, and

(c)

in relation to a merger within section 821(2)(c) or (d), the company to which assets and liabilities are transferred.

(4)

“Transparent entity” has the meaning given in section 820(4).

(5)

References to a company are references to any entity listed as a company in F1Part A of Annex I to the Mergers Directive.

(6)

In section 821 and this section “co-operative society” means a society registered under F2the Co-operative and Community Benefit Societies Act 2014 or a similar society governed by the law of a member State other than the United Kingdom.