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Amendment of section 615 of Principal Act (company reconstruction or amalgamation: transfer of assets)
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41. (1) Section 615 of the Principal Act is amended by inserting the following after subsection (4):
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“(4A) (a) In this subsection—
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‘arrangement’ includes any agreement, understanding, scheme, transaction or series of transactions (whether or not legally enforceable);
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‘tax’ means income tax, corporation tax or capital gains tax.
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(b) This section shall not apply to a scheme of reconstruction or amalgamation involving the transfer of the whole or part of a company’s business to another company unless it is shown that the reconstruction or amalgamation is effected for bona fide commercial reasons and does not form part of an arrangement the main purpose, or one of the main purposes, of which is the avoidance of liability to tax.”.
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(2) This section applies to disposals made on or after 22 October 2015.
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