Article 29 - Transfer of Licensed Activity Without Change in Ownership
(1) This Article applies where a
QFC Entity (the "predecessor") ceases to carry on a Licensed Activity, and another QFC Entity (the "successor") begins to carry it on, and at that time a Person with a 51% Interest in the predecessor has a 51% Interest in the successor which he continues to hold for at least 6 months from the date the successor begins to carry on the Licensed Activity.
(2) Subject to Article 29(3), tax losses available to the predecessor, and not utilised as at the date of transfer of the
Licensed Activity, shall be available to the successor as though they were losses carried forward under Article 28 as at the date of transfer.
(3) Tax losses transferred to the successor shall only be available against
Chargeable Profits arising from the Licensed Activity referred to in Article 29(1).
|Amended (as from 18th June 2014)|