{
  "url": "https://openlegislation.uk/taxes-management-act-1970/schedule-3ZC/paragraph-3",
  "json_url": "https://openlegislation.uk/taxes-management-act-1970/schedule-3ZC/paragraph-3.json",
  "legislation": "ukpga/1970/9",
  "legislation_title": "Taxes Management Act 1970",
  "legislation_url": "https://openlegislation.uk/taxes-management-act-1970",
  "path": "schedule/3ZC/paragraph/3",
  "kind": "paragraph",
  "number": "3",
  "heading": null,
  "text": "(1) For the purposes of this Schedule each of the following is a qualifying transaction of a company (“the company concerned”)—\n(a) a disposal within sub-paragraph (2),\n(b) a transaction within sub-paragraph (3),\n(c) a transaction within sub-paragraph (4), and\n(d) a transfer within sub-paragraph (5).\n(2) A disposal is within this sub-paragraph if—\n(a) it is a disposal by the company concerned of an asset,\n(b) it is a disposal to a company (“the transferee”) that at the time of the disposal is resident outside the United Kingdom in an EEA state, and\n(c) it is a disposal to which section 139 or 171 of TCGA 1992 would apply were the transferee resident at the time of the disposal in the United Kingdom instead.\n(3) A transaction is within this sub-paragraph if—\n(a) it is a transaction, or the first in a series of transactions, as a result of which the company concerned is directly or indirectly replaced as a party to a loan relationship by another company (“the transferee”),\n(b) at the time of the transaction the transferee is resident outside the United Kingdom in an EEA state, and\n(c) it is a transaction to which section 340(3) of CTA 2009 would apply were the transferee resident at the time of the transaction in the United Kingdom instead.\n(4) A transaction is within this sub-paragraph if—\n(a) it is a transaction, or the first in a series of transactions, as a result of which the company concerned is directly or indirectly replaced as a party to a derivative contract by another company (“the transferee”),\n(b) at the time of the transaction the transferee is resident outside the United Kingdom in an EEA state, and\n(c) it is a transaction to which section 625(3) of CTA 2009 would apply were the transferee resident at the time of the transaction in the United Kingdom instead.\n(5) A transfer is within this sub-paragraph if—\n(a) it is a transfer from the company concerned of an intangible fixed asset,\n(b) it is a transfer to a company (“the transferee”) that immediately after the transfer is resident outside the United Kingdom in an EEA state, and\n(c) it is a transfer to which section 775(1) of CTA 2009 would apply were the transferee resident immediately after the transfer in the United Kingdom instead.\n(6) In this Schedule “transferee”, in relation to a qualifying transaction of a company, means the transferee referred to in sub-paragraph (2), (3), (4) or (5) (as the case may be).",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "Sch. 3ZC inserted (retrospective and with effect in accordance with Sch. 7 para. 4(1)(a) of the amending Act) by Finance Act 2020 (c. 14), Sch. 7 para. 2"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/1970/9/schedule/3ZC/paragraph/3",
    "retrieved_at": "2026-10-29T10:51:31.747484+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."
}