{
  "url": "https://openlegislation.uk/corporation-tax-implementation-of-the-mergers-directive-regulations-2011/note",
  "json_url": "https://openlegislation.uk/corporation-tax-implementation-of-the-mergers-directive-regulations-2011/note.json",
  "legislation": "uksi/2011/1431",
  "legislation_title": "The Corporation Tax (Implementation of the Mergers Directive) Regulations 2011",
  "legislation_url": "https://openlegislation.uk/corporation-tax-implementation-of-the-mergers-directive-regulations-2011",
  "path": "note",
  "kind": "note",
  "number": null,
  "heading": "Explanatory note",
  "text": "(This note is not part of the Regulations)\nThe Regulations make consequential amendments to corporate tax legislation to take account of Council Directive 2009/133/EC. The Acts affected are the Taxation of Chargeable Gains Act 1992 (c. 12) (regulation 2), the Finance Act 2007 (c. 11) (regulation 3), the Corporation Tax Act 2009 (c. 4) (regulation 4) and the Taxation (International and Other Provisions) Act 2010 (c. 8) (regulation 5).\nThis is for the purpose of implementing the codifying Directive 2009/133/EC of the Council of the European Union of 19 October 2009 on cross border mergers of limited liability companies (OJ L 310 25.11.2009, p. 34) (“the Mergers Directive”).\nA transposition note has been prepared, which sets out how the main elements of the Mergers Directive have been transposed into UK law and is available from the CTIAA Directorate, HM Revenue and Customs (“HMRC”), 100 Parliament Street, London SW1A 2HQ. It is also available on the HMRC website (www.hmrc.gov.uk) and a copy has been placed in the Library of the House of Commons.\nIn line with government commitments, a Tax Information and Impact Note has not been prepared for this instrument as it gives effect to previously announced policy.",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/uksi/2011/1431/note",
    "retrieved_at": "2026-10-29T02:05:09.861193+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."
}