14 Reorganisations and reconstructions

An application under Article 46 (Reorganisations and Reconstructions Carried out for Bona Fide Commercial Reasons) shall be made in the return for the Accounting Period during which the reorganisation or reconstruction occurred and must contain the following information—

(A) full particulars of the transaction or transactions constituting the reorganisation or reconstruction;
(B) the date that the transaction or transactions constituting the reorganisation or reconstruction took place;
(C) copies of all relevant documents with the relevant parts or passages identified;
(D) the applicant's opinion of the tax consequences of the reorganisation or reconstruction, together with the reasons why it is considered those consequences should not apply, and the tax neutral treatment of Article 46 (Reorganisations and Reconstructions Carried out for Bona Fide Commercial Reasons) apply instead;
(E) the applicant's explanation of any particular point(s) of difficulty regarding the application; and
(F) details of the provisions of the Tax Regulations and these rules the applicant considers are relevant to the application.
Amended (as from 18th June 2014)