117 Tax treated as chargeable in respect of transfer of loan relationship, derivative contract or intangible fixed assets
Taxation (International and Other Provisions) Act 2010 (2010 c 8) | Legislation

117  Tax treated as chargeable in respect of transfer of loan relationship, derivative contract or intangible fixed assets

(1)     If tax would have been chargeable under the law of one or more . . . member States in respect of the transfer mentioned in section 116(2)(b)(i), (ii) or (iii) but for the Mergers Directive, this Part applies, and any double taxation arrangements apply, as if that tax had been chargeable.

(2)     In calculating tax notionally chargeable under subsection (1), it is to be assumed—

(a)     that,

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