SCHEDULE 1CROSS-BORDER TRANSFERS OF BUSINESS

PART 1AMENDMENTS OF TGCA 1992

Held over gains9

After section 179(1A) (company ceasing to be member of group: post appointment day cases)14 insert—

1AA

If shares in a company are transferred as part of the process of the transfer of a business to which section 140A or 140C applies and in consequence of the transfer the company ceases to be a member of a group (“Group 1”)—

a

the company shall not be treated for the purposes of this section as having left Group 1, and

b

if the transferee is a member of a group (“Group 2”) and in consequence of the transfer the company becomes a member of Group 2 it shall be treated, for the purposes of this section, as if Group 1 and Group 2 were the same.