Corporation Tax Act 2010 section 676EE

Interpretation of Chapter

Section 676EE provides the key definitions and interpretive rules needed to understand the terms used throughout this Chapter, including what constitutes a transfer of trade, a co-transferred company, and when two companies are considered related.

• The meaning of "transfer of trade" and related expressions follows the same definition used in Chapter 1 of Part 22 (as set out in section 940B).
• A "co-transferred company" is any company that is related to the transferred company both immediately before and immediately after the change in ownership takes place.
• Two companies are "related" if they satisfy either the group condition or any one of four consortium conditions, regardless of which company is treated as the claimant and which as the surrendering company.
• The group condition and consortium conditions 1 to 4 take their meaning from the group relief for carried-forward losses rules in sections 188CE to 188CI.