Corporation Tax Act 2010 section 994

Transfer of part of trade

Section 994 modifies the harbour reorganisation rules where only part of a trade, rather than the whole trade, is transferred to a harbour authority under a certified harbour reorganisation scheme.

• Where only part of a trade is transferred under a certified harbour reorganisation scheme, the normal full-transfer rules in section 991 are adapted to fit the partial transfer situation.
• The transferor is treated as if the part of the trade being transferred had always been a separate trade from the part that is retained.
• The section requires just and reasonable apportionments to be made in order to split relevant tax amounts between the transferred part and the retained part of the trade.
• This approach ensures that tax reliefs and obligations are divided fairly between the harbour authority receiving the trade and the original owner continuing with the remainder.

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