Taxes Management Act 1970 section 3

Qualifying transactions

Section 3 of Schedule 3ZC defines the four types of transaction that can qualify a company for the corporation tax payment plan, all of which involve a transfer to a company resident in an EEA state outside the United Kingdom.

• Asset disposals to EEA-resident companies that would otherwise qualify for tax-neutral treatment under reconstruction or group transfer rules had the receiving company been UK-resident
• Loan relationship transfers where the company is replaced as a party by an EEA-resident company, and the transaction would qualify for group continuity treatment had the receiving company been UK-resident
• Derivative contract transfers where the company is replaced as a party by an EEA-resident company, and the transaction would qualify for group continuity treatment had the receiving company been UK-resident
• Intangible fixed asset transfers to EEA-resident companies that would qualify for intra-group relief had the receiving company been UK-resident immediately after the transfer