Market leading insight for tax experts
View online issue

Transfers of trade and reconstructions

Speed read

Where a trade is transferred from one company to another and at least a 75% interest in it belongs to the same person at some time in the year before the transfer and in the two years following the transfer and the trade is within the charge to UK tax throughout this time, then trading losses can be transferred with the trade. Capital allowances will be transferred with the trade and allowances for the year of transfer will be time apportioned. Stock will be transferred at the price paid unless it is transferred to someone not trading in the UK or a connected party, in which case OMV will apply. Connected parties can elect to have stock treated as transferred at the higher of cost and price received provided that market value is greater than both selling price and cost.

If you or your firm subscribes to, please click the login box below:

If you do not subscribe but are a registered user, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Please reach out to customer services at +44 (0) 330 161 1234 or '' for further assistance.