Withdrawal of relief on subsequent non-exempt transferS
22SRelief under Part 2 or Part 3 of this schedule is withdrawn or partially withdrawn if—
(a)control of the acquiring company changes as a result of an exempt intra-group transfer, and
(b)paragraphs 23 and 24 apply.
Commencement Information
I1 Sch. 11 para. 22 in force at 1.4.2015 by S.S.I. 2015/108 , art. 2
23SThis paragraph applies where a company holding shares in the acquiring company to which the exempt intra-group transfer related, or that are derived from shares to which that transfer related, ceases to be a member of the same group as the target company—
(a)before the end of the period of 3 years beginning with the effective date of the transaction which is exempt from charge by virtue of Part 2, or is subject to a reduced amount of tax by virtue of Part 3, of this schedule (“the relevant transaction”), or
(b)in pursuance of, or in connection with, arrangements made before the end of that period.
Commencement Information
I2 Sch. 11 para. 23 in force at 1.4.2015 by S.S.I. 2015/108 , art. 2
24SThis paragraph applies where the acquiring company or a relevant associated company, at that time (“the relevant time”), holds a chargeable interest—
(a)that was transferred to the acquiring company by the relevant transaction, or
(b)that is derived from an interest so transferred,
and that has not subsequently been transferred at market value under a chargeable transaction in relation to which relief under Part 2 or Part 3 of this schedule was available but was not claimed.
Commencement Information
I3 Sch. 11 para. 24 in force at 1.4.2015 by S.S.I. 2015/108 , art. 2