Article 6 Corporation tax: computation of profits and losses in respect of transfer of trade
This article applies where BWB is carrying on a trade or part of a trade and, as a result of a relevant transfer—
BWB ceases to carry on that trade or part of a trade, and
CRT or CRT CIC begins to carry on that trade or part.
For the purposes of computing, in relation to the time when a relevant transfer takes effect and at subsequent times, the relevant trading profits or losses of BWB and CRT, or CRT CIC,—
the trade or part is to be treated as having been a separate trade at the time of its commencement and as having been carried on by CRT or CRT CIC at all times since its commencement as a separate trade, and
the trade carried on by CRT or CRT CIC after the time when a relevant transfer takes effect is to be treated as the same trade as that which CRT or CRT CIC is treated, by virtue of sub-paragraph (a), as having carried on as a separate trade before that time.
Where a trade or part of a trade falls to be treated under this article as a separate trade, such apportionments of receipts, expenses, assets, and liabilities are to be made for the purposes of computing relevant trading profits or losses as may be just and reasonable.
In this article “relevant trading profits or losses” means profits or losses under Part 3 of CTA 2009 in respect of the trade or part of a trade in question.