1. Introductory Text

2. 1. Citation, commencement and effect

3. 2. Interpretation

4. 3. Amendments of primary legislation

5. Signature

6. 1. SCHEDULE 1

      CROSS-BORDER TRANSFERS OF BUSINESS

      1. PART 1 AMENDMENTS OF TGCA 1992

         1. 1. TCGA 1992 is amended as follows.

         2. 2. Division of UK business

         3. 3. In section 140B (section 140A: anti-avoidance)— (a) for “company A”...

         4. 4. Division of non-UK business

         5. 5. In section 140D (section 140C: anti-avoidance)— (a) for “company A”...

         6. 6. Treatment of securities issued on transfer of assets

         7. 7. Held over gains

         8. 8. After section 154(2C) (new assets which are depreciating assets) (inserted...

         9. 9. After section 179(1A) (company ceasing to be member of group:...

         10. 10. Loan relationships

      2. PART 2 AMENDMENTS OF ICTA

         1. 11. ICTA is amended as follows.

         2. 12. Exempt distributions

         3. 13. After section 213 (exempt distributions) insert— Exempt distributions: division of...

         4. 14. In section 218(1) (interpretation of sections 213 to 217)—

      3. PART 3 AMENDMENTS OF FA 1996

         1. 15. Schedule 9 to FA 1996 (loan relationships: special computational provisions)...

         2. 16. Loan relationships

         3. 17. In paragraph 12A (transferee leaving group) —

      4. PART 4 AMENDMENTS OF FA 2002

         1. 18. FA 2002 is amended as follows.

         2. 19. Derivative contracts

         3. 20. (1) Paragraph 30A of Schedule 26 (transferee leaving group) is...

         4. 21. Intangible fixed assets

         5. 22. (1) Paragraph 87 of Schedule 29 (transfer of non-UK trade)...

         6. 23. After paragraph 58(5) of Schedule 29 insert—

         7. 24. In paragraph 127 (certain assets to be treated as existing...

      5. PART 5 AMENDMENT OF CAA 2001

         1. 25. Capital allowances

   2. SCHEDULE 2

      EUROPEAN CROSS-BORDER MERGERS

      1. PART 1 AMENDMENTS OF TCGA 1992

         1. 1. TCGA 1992 is amended as follows.

         2. 2. For sections 140E (merger leaving assets in the UK tax...

         3. 3. In section 24(1) (destruction &c. of asset) for “section 144”...

         4. 4. After section 122(1) (capital distributions) insert— (1A) Subsection (1) is...

         5. 5. Held over gains

         6. 6. For section 154(2A) and (2B) (new assets which are depreciating...

         7. 7. For section 179(1B) and (1C) (de-grouping charge) substitute—

      2. PART 2 AMENDMENTS OF FA 1996

         1. 8. Loan relationships

      3. PART 3 AMENDMENTS OF FA 2002

         1. 9. FA 2002 is amended as follows.

         2. 10. Derivative contracts

         3. 11. Intangible assets

         4. 12. For paragraph 87A of Schedule 29 (SEs: transfer of non-UK...

         5. 13. In paragraph 88(1) and (5) of Schedule 29 (procedure on...

      4. PART 4 AMENDMENTS OF CAA 2001, FA 1988 AND ICTA

         1. 14. Capital allowances

         2. 15. Residence of SCE

         3. 16. Tax treatment of SCE

   3. SCHEDULE 3

      MERGERS, &C.: TREATMENT OF TRANSPARENT ENTITIES

      1. PART 1 AMENDMENT OF TCGA 1992

         1. 1. Chargeable gains

      2. PART 2 AMENDMENT OF FA 1996

         1. 2. Loan relationships

      3. PART 3 AMENDMENTS OF FA 2002

         1. 3. Derivative contracts

         2. 4. After paragraph 30F of Schedule 26 (European cross-border mergers) (inserted...

         3. 5. Intangible assets

7. Explanatory Note