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Taxation (International and Other Provisions) Act 2010 section 119
Tax treated as chargeable in respect of transfer of loan relationship, derivative contract or intangible fixed assets
Section 119 ensures that, for double taxation relief purposes, tax is treated as if it had been chargeable on transfers of loan relationships, derivative contracts or intangible fixed assets where such tax was only waived because of the EU Mergers Directive.
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