Section 828 — Corporation Tax Act 2009: Relief on transfer

Relief on transfer 828 1 If the proceeds of realisation of a relevant asset exceed the cost of the asset recognised for tax purposes, the proceeds are treated as reduced.

2 If the securities are the whole consideration for the transfer, the reduction is by the amount of the excess.

3 If the securities are not the whole of that consideration, the reduction is by the appropriate proportion of the excess.

4 In subsection (3) “ the appropriate proportion ” means the proportion that the market value of the securities at the time of the transfer bears to the market value of the whole of the consideration at that time.