Section 1078 — Corporation Tax Act 2010: Division of business in a cross-border transfer

Division of business in a cross-border transfer 1078 1 This section applies to a distribution which consists of—

a the transfer of part of a business by a company to one or more other companies (“the transferee company or companies”),

and b the issue of shares by the transferee company or companies to the members of the company making the transfer.

2 A distribution to which this section applies is an exempt distribution if either—

a each of the tests in paragraphs (a) to (f) of section 140A(1A) of TCGA 1992 (cross-border transfers: division of UK business) is met in relation to it, or b each of the tests in paragraphs (a) to (e) of section 140C(1A) of TCGA 1992 (cross-border transfers: division of non-UK business) is met in relation to it.