PART 2THE TAX AND KEY CONCEPTS
CHAPTER 4CHARGEABLE TRANSACTIONS AND CHARGEABLE CONSIDERATION
Chargeable consideration
I123Exceptions
1
Section 22 (deemed market value) does not apply in the following cases.
2
Case 1 is where immediately after the transaction the company holds the property as trustee in the course of a business carried on by it that consists of or includes the management of trusts.
3
Case 2 is where—
a
immediately after the transaction the company holds the property as trustee, and
b
the seller is connected with the company only because of section 1122(6) of the Corporation Tax Act 2010 (c. 4).
4
Case 3 is where—
a
the seller is a company and the transaction is, or is part of, a distribution of the assets of that company (whether or not in connection with its winding up), and
b
it is not the case that—
i
the subject-matter of the transaction, or
ii
an interest from which that interest is derived,
has, within the period of 3 years immediately preceding the effective date of the transaction, been the subject of a transaction in respect of which group relief under Schedule 16 was claimed by the seller.
5
In this section, “"the company”” means the company that is the buyer in relation to the transaction in question.