VCM90270 - CVS: general: qualifying issuing companies: liquidation and receivership

FA00/SCH15/PARA24

If:

• a resolution is passed, or an order is made, for the winding up of the company (or any act is done for the same purpose),

or

• the company is dissolved without winding up,

the company cannot be regarded as continuing to exist for the purpose of carrying on a trade.

Similarly, if a company goes into administration or receivership, the actions of the administrator or receiver may have the same result.

Nevertheless, such a company is to be treated as continuing to exist for the purpose of carrying on a trade provided the winding up or dissolution, or the actions of the administrator or receiver, are for genuine commercial reasons, and not part of an arrangement for avoiding tax.