Taxation (International and Other Provisions) Act 2010 Explanatory Notes

Section 121: Tax treated as chargeable in respect of relevant transactions

254.This section provides for tax to be treated as chargeable, for DTR purposes, in respect of the transfer of loan relationships, derivative contracts or intangible fixed assets if tax would have been chargeable but for the Mergers Directive. It is based on section 807G of ICTA.

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