{
  "url": "https://openlegislation.uk/eu-directive-2009-133/article-7",
  "json_url": "https://openlegislation.uk/eu-directive-2009-133/article-7.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/7",
  "kind": "article",
  "number": "7",
  "heading": null,
  "text": "1. Where the receiving company has a holding in the capital of the transferring company, any gains accruing to the receiving company on the cancellation of its holding shall not be liable to any taxation.\n2. The Member States may derogate from paragraph 1 where the receiving company has a holding of less than 15 % in the capital of the transferring company.\nFrom 1 January 2009 the minimum holding percentage shall be 10 %.",
  "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/7",
    "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."
}