Related Commentary  Related HMRC Manuals

116(1)  Subject to subsections (4) to (6), section 117 applies if condition A or B is met.

116(2)  Condition A is that–

(a)a company resident in the United Kingdom transfers to a company resident in a member State the whole or part of a business which immediately before the transfer the transferor carried on in a member State through a permanent establishment, and

(b)the transfer includes–

(i)the transfer of an asset or liability representing a loan relationship,

(ii)the transfer of rights and liabilities under a derivative contract, or

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