# Taxation of Chargeable Gains Act 1992, Paragraph 10A


(1) 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.
(2) For the purposes of this paragraph—
(a) 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—
(i) some or all of the assets of the company are available primarily, or only, to meet particular liabilities of the company, and
(ii) 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;
(b) “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.

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Source: https://www.legislation.gov.uk/ukpga/1992/12/schedule/1A/paragraph/10A (the official version)
Page: https://openlegislation.uk/taxation-of-chargeable-gains-act-1992/schedule-1A/paragraph-10A
Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives.