The application of TCGA92/S139 is subject to anti-avoidance provisions. Section 139(5) provides Section 139 will not apply unless

the scheme of reconstruction or amalgamation is effected for bona fide commercial reasons and

does not form part of a scheme or arrangements of which the main purpose, or one of the main purposes, is avoidance of liability to corporation tax, capital gains tax or income tax.

The anti-avoidance provisions of TCGA92/S139 are subject to an advance clearance procedure which is identical to that which applies to TCGA92/S135 and TCGA92/S136. Instructions on the clearance procedures can be found at CG52631.

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