Related Commentary  Related HMRC Manuals

674(1)  This Chapter applies if–

(a)condition A or B is met, and

(b)each of the companies mentioned in subsection (2)(a) or (3)(a) makes a claim under this section,

but see section 677 (tax avoidance etc) and section 680 (disapplication of Chapter where transparent entities involved).

674(2)  Condition A is that–

(a)a company resident in one relevant state transfers to a company resident in another relevant state the whole or part of a business carried on in the United Kingdom,

(b)the transfer is wholly in exchange for shares or debentures issued by the transferee to the transferor, and

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