211 Transfer of assets or liabilities to a member of a multinational group

211  Transfer of assets or liabilities to a member of a multinational group

[(1)     Subsection (1A) applies where there has been a transfer of assets or liabilities to a member of a multinational group and—

(a)     the transfer forms part of a qualifying reorganisation (see section 212), or

(b)     the transferor is a member of the group and—

(i)     the transferee is located in the same territory as the transferor,

(ii)     the transferee and transferor are included in the same tax consolidation group in that territory (within the meaning of section 164(5)), and

(iii)     an election under section 164 (election to exclude intra-group transactions) has

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