Taxation (International and Other Provisions) Act 2010 section 122

Tax treated as chargeable in respect of gains on transfer of non-UK business

Section 122 provides relief for notional foreign tax that would have been charged on gains arising from transfers of non-UK businesses, parts of non-UK businesses, or cross-border mergers, were it not for the EU Mergers Directive exempting those gains from tax in the host country.

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