Section 210 Transfer of assets or liabilities from a member of a multinational group

Where a member of a multinational group transfers assets or liabilities to another entity in the course of a qualifying reorganisation (see section 212), any gain or loss on the transfer is to be excluded from the adjusted profits of the member, except to the extent it is a non-qualifying gain or loss.

In this section, and in sections 211 and 212, “non-qualifying gain or loss” means a gain or loss of the F1transferor on the transfer of assets or liabilities, and is the lesser of—