Corporation Tax Act 2009 section 790

Provisions supplementing section 789

Section 790 provides supplementary interpretation rules that support the definition of a qualifying merger under section 789, clarifying key terms and how certain tests are to be applied.

• The term "arrangement" in section 789 is broad enough to cover a series of arrangements, not just a single transaction
• When assessing whether the merger conditions are met, all activities of a company group are treated as a single business carried on by each member
• The value of any interest acquired is fixed at the date of acquisition for the purposes of the relevant value tests in section 789
• Any part of the consideration for an acquisition that is small relative to the total consideration can be disregarded when applying the consideration test in section 789(6)