TCGA 1992, s. 140A–140L provide chargeable gains tax relief to a transferor company and, in certain circumstances, to its shareholders in relation to a broad range of restructuring transactions involving participants resident in different states of either the UK or EU (relevant states) (TCGA 1992, s. 140L). Before IP completion day (31 December 2020), the reference to different relevant states was to “different EU member states” thus ensuring continuity of treatment.

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