CG45704 explains how a charge could arise to a parent company under TCGA 1992 section 24 or section 122 where there has been a partial division or a merger to which sections 140A(1A), or section 140C(1A), or section 140E or section 140F can apply and the transferee parent company cannot issue its own shares to itself.

That particular problem could also arise where a parent company, which is to be the transferee in a merger, holds 100% of the shares in a non UK resident transferor company.

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