Corporation Tax Act 2010 section 676EA

Introduction to Chapter

Section 676EA introduces the Chapter and establishes that its provisions apply where there is a change in ownership of a company on or after 1 April 2017.

  • The Chapter applies when there is a change in the ownership of a company occurring on or after 1 April 2017.
  • The company whose ownership changes is referred to throughout the Chapter as "the transferred company".
  • The term "change in ownership" is used consistently throughout the Chapter to describe the ownership change that triggers the application of these rules.
  • Both defined terms — "the transferred company" and "the change in ownership" — carry the same meaning wherever they appear in the Chapter.

Example

Company A is a UK trading company. On 15 June 2018, all of the shares in Company A are acquired by Company B. Because this change in ownership occurs after 1 April 2017, the Chapter applies. Company A is "the transferred company" and the acquisition of its shares by Company B is "the change in ownership". The remaining provisions of the Chapter must then be considered to determine the corporation tax implications for Company A.

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