{
  "url": "https://openlegislation.uk/corporation-tax-act-2010/section-1066",
  "json_url": "https://openlegislation.uk/corporation-tax-act-2010/section-1066.json",
  "legislation": "ukpga/2010/4",
  "legislation_title": "Corporation Tax Act 2010",
  "legislation_url": "https://openlegislation.uk/corporation-tax-act-2010",
  "path": "section/1066",
  "kind": "section",
  "number": "1066",
  "heading": "Exception for certain transfers between UK resident companies",
  "text": "(1) Section 1064 does not apply if the company and the participator are both UK resident and—\n(a) one is a 51% subsidiary of the other or both are 51% subsidiaries of a third company which is also UK resident, and\n(b) the benefit to the participator arises on a transfer of assets or liabilities—\n(i) by the company to the participator, or\n(ii) to the company by the participator,\nor in connection with such a transfer.\n(2) In determining whether one body corporate (“A”) is a 51% subsidiary of another (“B”) for the purposes of subsection (1), B is treated as not being the owner of—\n(a) any share capital which it owns directly in a body corporate as trading stock,\n(b) any share capital which it owns indirectly, and which is owned directly by a body corporate as trading stock, or\n(c) any share capital which it owns directly or indirectly in a body corporate that is not UK resident.\n(3) For the purposes of subsection (2) share capital owned by a body is owned as trading stock if (and only if) a profit on the sale of the shares would be treated as a trading receipt of the body's trade.",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2010/4/section/1066",
    "retrieved_at": "2026-10-29T09:10:29.433154+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}