Paragraph 10A F1F2
In the application of this Schedule in relation to the disposal of an asset consisting of a right or an interest in a cell company, each cell of the company is to be treated as if it were an individual company.
For the purposes of this paragraph—
a company is a “cell company” if under the law under which the company is formed, under the company’s articles of association or other document regulating the company or under arrangements entered into by or in relation to the company—
some or all of the assets of the company are available primarily, or only, to meet particular liabilities of the company, and
some or all of the members of the company, and some or all of its creditors, have rights primarily, or only, in relation to particular assets of the company;
“cell”, in relation a cell company, means an identifiable part of the company that carries on distinct business activities and to which particular assets and liabilities of the company are primarily or wholly attributable.
Annotations
Textual amendments
- F1
Sch. 1A inserted (with effect in accordance with Sch. 1 paras. 120, 123 of the amending Act) by Finance Act 2019 (c. 1), Sch. 1 para. 14
- F2
Sch. 1A para. 10A and cross-headings inserted (with effect in accordance with s. 40(4) of the amending Act) by Finance Act 2026 (c. 11), s. 40(3)(4)
Notes on Part 4
Textual amendments
- F2
Sch. 1A Pt. 4 heading substituted (with effect in accordance with s. 40(4) of the amending Act) by Finance Act 2026 (c. 11), s. 40(2)(4)