Commentary on Sections Overview Overview Section 119: Tax treated as chargeable in respect of transfer of loan relationship, derivative contract or intangible fixed assets
252.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 sections 807D(12) and 807E of ICTA.