Related Commentary  Related HMRC Manuals

140(1)  This section applies where a company resident in the United Kingdom carries on a trade outside the United Kingdom through a permanent establishment and–

(a)that trade, or part of it, together with the whole assets of the company used for the purposes of the trade or part (or together with the whole of those assets other than cash) is transferred to a company not resident in the United Kingdom;

(b)the trade or part is so transferred wholly or partly in exchange for securities consisting of shares, or of shares and loan stock, issued by the transferee company to the transferor company;

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