Corporation Tax Act 2010 section 395

No qualifying change of ownership in certain intra-group reorganisations

Section 395 ensures that certain internal group reorganisations do not trigger a qualifying change of ownership for the purposes of the sales of lessors rules.

• The section applies where there is a relevant change in the relationship between a company ("Company A") and its principal company on a particular day.
• The change arises because Company A or another company ceases to be a qualifying 75% subsidiary on that day.
• Company A and every other company involved in the change must remain qualifying 75% subsidiaries of the same principal company at both the start and end of that day.
• Where these conditions are met, no qualifying change of ownership of Company A is treated as occurring on that day as a result of the reorganisation.