CTM34400 - Residence: avoidance transactions: special consent: examples

ICTA88/S765 and ICTA88/S765A

Some examples of transactions needing special consent are:

• the transfer by a UK resident company of shares in a non-resident subsidiary to another non-resident subsidiary,
• the making of a deep discount loan by a UK resident company to a non-resident subsidiary, provided that involves the issue of a debenture by the latter company,
• the making of a loan by one non-resident subsidiary to another non-resident subsidiary which is resident in a different country, provided there is an issue of a debenture by the second subsidiary.

See also ITH1300+.