Transfer of trade without a change of ownership

Where a trade is transferred between companies within the charge to tax and certain conditions about common ownership are met (i.e. company reconstruction without change of ownership), capital allowances are calculated as if the successor had always carried on the trade and owned the assets in question. The rules in CTA 2010, s. 948 do not apply in the following cases:

the successor is a dual resident investing company (CTA 2010, s. 949);

the transferred trade is or forms part of a business of leasing plant or machinery (CTA 2010, s. 950);

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