Explanatory Notes

Corporation Tax Act 2010

2010 CHAPTER 4

3 March 2010

Introduction

Part 4: Loss relief

Chapter 5: Losses on disposal of shares
Section 87: Relief after an exchange of shares for shares in another company

309.This section and section 88 provide for continuity of the application of the requirements in sections 79 to 85 in the case of certain reconstructions which result in the issue of shares in a new company in exchange for shares in another company but do not involve any change in ownership of the underlying business. This section is based on section 576J of ICTA.

310.Subsection (3)(a) is new and resolves the apparent conflict between section 74 and this section. See Change 19 in Annex 1.