Corporation Tax Act 2010 section 991

Harbour reorganisation schemes: corporation tax

Section 991 provides corporation tax relief where a trade is transferred to a harbour authority under a harbour reorganisation scheme, allowing the trade to be treated as continuing and losses to pass to the new owner.

• Where a trade is transferred to a harbour authority under a harbour reorganisation scheme, the trade can be certified as not having ceased, preserving its continuity for corporation tax purposes.
• Any tax losses that would have been available to the original owner (the transferor) for relief may instead be used by the new owner (the transferee harbour authority).
• The relief only applies where the trade is transferred from a body corporate that is not a limited liability company, meaning this provision has a very narrow scope in practice.
• This section is the first of five related sections dealing with the corporation tax consequences of transferring a trade under a harbour reorganisation scheme.

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