{
  "url": "https://openlegislation.uk/eu-directive-2009-133/article-5",
  "json_url": "https://openlegislation.uk/eu-directive-2009-133/article-5.json",
  "legislation": "eudr/2009/133",
  "legislation_title": "Council Directive 2009/133/EC of 19 October 2009 on the common system of taxation applicable to mergers, divisions, partial divisions, transfers of assets and exchanges of shares concerning companies of different Member States and to the transfer of the registered office of an SE or SCE between Member States (codified version)",
  "legislation_url": "https://openlegislation.uk/eu-directive-2009-133",
  "path": "article/5",
  "kind": "article",
  "number": "5",
  "heading": null,
  "text": "The Member States shall take the necessary measures to ensure that, where provisions or reserves properly constituted by the transferring company are partly or wholly exempt from tax and are not derived from permanent establishments abroad, such provisions or reserves may be carried over, with the same tax exemption, by the permanent establishments of the receiving company which are situated in the Member State of the transferring company, the receiving company thereby assuming the rights and obligations of the transferring company.",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/eudr/2009/133/article/5",
    "retrieved_at": "2026-11-01T15:22:05.979034+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."
}