Link Report

(1) Notwithstanding section 78(2) a pre-entry loss that accrued to a company on a disposal before the company became a member of the relevant group shall only be deductible from a chargeable gain accruing to the company where the gain is one accruing—

(2) Notwithstanding section 78(2) the pre-entry proportion of an allowable loss accruing to a company on the disposal of a pre-entry asset shall only be deductible from a chargeable gain accruing to the company where—

(a) the principal company of a group of companies (in this paragraph referred to as “the first group”) has at any time become a member of another group (in this paragraph referred to as “the second group”) so that the two groups are treated as the same by virtue of subsection (3)or (3A)of section 616, and

(b) since that time the asset has been disposed of otherwise than by a disposal to which section 617 applies,

but, without prejudice to subparagraph (8), where, on a disposal to which section 617 does not apply, an asset would cease to be a pre-entry asset by virtue of this subparagraph and the company making the disposal retains any interest in or over the asset in question, that interest shall be a pre-entry asset for the purposes of this Schedule.

Section 626A

(A) the SE as part of the process of its formation by the merger by acquisition of two or more companies in accordance with Articles 2(1) and 17(2)(a) or (b) of the SE Regulation (within the meaning of section 630), or

(B) the SCE as part of the process of its formation by merger in accordance with Article 2 of the SCE Regulation (within the meaning of section 630),

(9) In determining for the purposes of this Schedule whether an allowable loss accruing to a company on a disposal under section 719 or section 738(4)(a) is a loss that accrued before the company became a member of the relevant group, the provisions of section 720 or section 738(4)(b), as the case may be, shall be disregarded.

(9) In determining for the purposes of this Schedule whether an allowable loss accruing to a company on a disposal under section 719 or section 738(4)(a) is a loss that accrued before the company became a member of the relevant group, the provisions of section 720 or section 738(4)(b), as the case may be, shall be disregarded.

(9) In determining for the purposes of this Schedule whether an allowable loss accruing to a company on a disposal under section 719 or section 738(4)(a) is a loss that accrued before the company became a member of the relevant group, the provisions of section 720 or section 738(4)(b), as the case may be, shall be disregarded.

(9) In determining for the purposes of this Schedule whether an allowable loss accruing to a company on a disposal under section 719 or section 738(4)(a) is a loss that accrued before the company became a member of the relevant group, the provisions of section 720 or section 738(4)(b), as the case may be, shall be disregarded.