Related Commentary  Related HMRC Manuals


In the title to s. 181, the word “section” was omitted apparently by error and has been inserted by Croner-i.

181(1)  Subject to the following provisions of this section, section 179 shall not apply in a case where–

(a)as part of a merger, a company (“company A” ) ceases to be a member of a group of companies (“the A group” ); and

(b)the merger was carried out for bona fide commercial reasons and the avoidance of liability to tax was not the main or one of the main purposes of the merger.

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