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HMRC internal manual

Company Taxation Manual

HM Revenue & Customs
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Corporation Tax: company reconstructions: without change in ownership - later events


CTA10/S953 provides a further situation in which CTA10/S940A treatment should be applied, if necessary re-opening computations to do so. However cases where CTA10/S953 applies are rare.

It does apply where:

  • a transfer of a trade or part-trade between two companies never meets the common ownership test,


  • within the next two years there is a further transfer to a third company.

CTA10/S953 is satisfied if common ownership of the trade is established between the first and third companies under the normal one- and two-year time span explained at CTM06010. However this time span is fixed by reference to the first transfer of trade.

When the conditions of CTA10/S953 are met, CTA10/S940A applies to both transfers. This means, for example, that any unused losses of the first company are deductible against any profits the second company may have from the transferred trade or part-trade before it was transferred to the third company.