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A company wholly owned by a City Council has queried whether unallocated subsidies and the global transfer of assets and liabilities qualify for the 99% Corporation Tax relief. The Directorate General for Taxes (DGT) has ruled that this relief applies only to income from specific public services and does not extend to income derived from market valuations during liquidation.
This ruling limits the scope of the 99% tax relief, clarifying that it is restricted to specific public service activities rather than general asset transfers or market value adjustments during the winding-up process.
The tax team reviews your specific situation.
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