Corporation Tax Act 2009 section 770

Continuity: formation of an SE before 1 April 2005

Section 770, which provides for continuity of treatment where a group includes a Societas Europaea (SE), is disapplied where the SE was formed before 1 April 2005.

• Section 770 deals with continuity of tax treatment where a corporate group includes a Societas Europaea (SE)
• This continuity rule does not apply where the SE was formed before 1 April 2005
• The exclusion covers all methods of forming an SE, including formation by transformation of an existing company
• For SEs formed on or after 1 April 2005, the normal continuity rules under section 770 apply