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Taxation (International and Other Provisions) Act 2010

Section 180: Application of section 174(2)(a) in relation to transfers of trading stock etc

371.This section provides for a broad timing match between the adjustments arising on the advantaged and disadvantaged company where there is a transfer of stock between the two. It is based on paragraph 6A of Schedule 28AA to ICTA.

372.A mismatch in timing may arise with stock transfers because, while an increase to open market value of the stock transferred will immediately result in an increase to the transferor company’s profits, the compensating adjustment will not arise in the case of the transferee company until that stock has been disposed of.

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