# Corporation Tax Act 2010, Section 945: Cases in which predecessor retains more liabilities than assets

Extent: E+W+S+N.I.

(1) This section applies if L exceeds A.
(2) “L” is the amount of the predecessor's liabilities so far as they—
(a) are outstanding immediately before the transfer of the transferred trade, and
(b) are not transferred to the successor on the transfer of the trade.
(3) “A” is the sum of the values of—
(a) the predecessor's assets immediately before the transfer of the transferred trade so far as they are not transferred to the successor on that transfer, and
(b) the consideration given to the predecessor by the successor in relation to the transfer of the transferred trade.
(4) The relief to be given to the successor as a result of sections 944 to 944E is limited to—
R-Ewhere—
R is the total amount of loss for which relief could be given to the successor as a result of sections 944 to 944E, ignoring this section, and
E is the amount by which L exceeds A.
(5) If R does not exceed E, no relief is to be given to the successor.

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Source: https://www.legislation.gov.uk/ukpga/2010/4/section/945 (the official version)
Page: https://openlegislation.uk/corporation-tax-act-2010/section-945
Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives.