Regulation 4 Transfers from LTGDC to LLDC

(1)

This regulation applies to a LTGDC relevant transfer.

(2)

Paragraphs (3) and (4) have effect in computing for any corporation tax purpose both—

(a)

the profits of LTGDC’s trade in relation to which the stock transferred is trading stock immediately before the relevant transfer takes effect, and

(b)

the consideration given by LLDC, or the expenditure incurred by it, for the acquisition of the stock.

(3)

The stock must be taken to have been—

(a)

disposed of by LTGDC in the course of its trade, and

(b)

disposed of and acquired when the relevant transfer takes effect.

(4)

The stock must be valued as if the disposal and acquisition were for a consideration which in relation to LTGDC would have resulted in neither a profit nor a loss being brought into account in respect of the disposal in the accounting period of LTGDC which ends with, or is current at, the time when the relevant transfer takes effect.