Commentary on Sections Part One: Sale of the Tote Section 4: Tax
23.Subsection (1) provides that for all income tax, corporation tax and capital gains tax purposes the successor company is to be treated as if it had always been the Tote, and the transfer itself will not have any tax consequences.
24.Subsection (2) ensures that liability to stamp duty or stamp duty land tax does not arise on the vesting of the Tote’s property in the successor company, or on certain preliminary transactions and subsection (3) ensures that group relief in respect of stamp duty and stamp duty land tax is unaffected by the vesting provisions of Part 1.