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HMRC internal manual

Business Leasing Manual

From
HM Revenue & Customs
Updated
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Sale of lessor companies and similar arrangements: partnerships: change in ownership of a partner company - identifying ‘ relevant transferred plant or machinery’

Section 411 CTA2010

In a case where there is a change in ownership of a partner company the rules identify assets transferred from any company associated with the partner.

Example: change in ownership of partner

Insert’ attachment at BLM81050A’ here

In this example there is a change in ownership of both partners A Ltd and B Ltd. The companies associated with A Ltd and B Ltd are C Ltd and D Ltd.

  • A Ltd is the partner company;
  • C Ltd is an associated company of A Ltd;
  • B Ltd is the other partner company in relation to which there is a qualifying change of ownership
  • D Ltd is an associated company of B Ltd.