Commentary on Sections Overview Overview Section 117: Tax treated as chargeable in respect of transfer of loan relationship, derivative contract or intangible fixed assets
250.This section provides for tax to be treated as chargeable, for DTR purposes, in respect of the transfer of loan relationships, derivative contracts or intangible fixed assets if tax would have been chargeable but for the Mergers Directive. It is based on section 807C of ICTA.