Where there is a transfer of a business between UK-resident companies as part of a reconstruction or amalgamation and the transferor does not receive any consideration for the transfer, a relief is available in respect of the chargeable gains arising on the transfer. However, the relief may be denied if the reconstruction or amalgamation is not effected for bona fide commercial reasons or forms part of a scheme or arrangements of which one of the main purposes is avoidance of tax (see ¶762-900).

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