MTT44000 - Particular entities and adjustments: Restructures: Contents
MTT is applied to groups rather than individual entities. Where the composition of the group changes, certain additional provisions are required. These are contained within sections 208 to 212 Finance (No.2) Act 2023. These cover situations where:
- a member joins or leaves a group
- a transfer of a controlling interest is treated as acquisition of assets and liabilities
- assets are transferred between members of a group
44010: Member joining or leaving a group
This section of guidance explains how to apply the MTT rules to a member that has joined or left a group.
Certain adjustments are required in relation to:
- deferred tax assets and liabilities of the entity
- purchase accounting consolidation adjustments relating to the transfer of the entity
- the eligible tangible asset amount of the entity
44020: Transfer of controlling interest treated as acquisition of assets and liabilities
This section of guidance explains an exception to the rules in MTT44010, under which the acquisition or disposal should instead be treated as an acquisition or disposal of assets or liabilities.
44030 and 44040: Transfers of assets or liabilities
This section of guidance explains how to apply the Pillar 2 rules where there is a transfer of assets or liabilities during a qualifying reorganisation.