The rules in FA00/SCH23 do not apply to IRUs acquired, directly or indirectly, from associates or associated companies on or after 21 March 2000 if the associate or associated company acquired the IRU before that date.
Domodossola Ltd, Empoli Ltd and Fano Ltd are companies
associated with each other.
On 1 March 2000 Domodossola Ltd acquires an IRU from a third
party. On 21 March 2000 Domodossola Ltd sells the IRU to Empoli
Ltd. On 31 March 2001 Empoli Ltd sells it to Fano Ltd.
The rules in FA00/SCH23 do not apply to Domodossola Ltd's
acquisition of the IRU because it was acquired before 21 March
2000.
The rules in FA00/SCH23 do not apply to Empoli Ltd's
acquisition of the IRU as it was acquired directly from an
associated company (Domodossola Ltd), which acquired the IRU before
21 March 2000.
The rules in FA00/SCH23 do not apply to Fano Ltd's
acquisition of the IRU as it was acquired indirectly from an
associated company (Domodossola Ltd), which acquired the IRU before
21 March 2000.