CFM77060 - Other tax rules on corporate debt: transfers of income streams: company transferors: relevant amount
Company transferors: relevant amount
CTA10/S753(2) defines the 바카라 사이트˜relevant amount바카라 사이트™. This is normally the amount of the consideration for the transfer of the right to the relevant receipts. But where the amount of the consideration is substantially less than the market value of the right to the relevant receipts (or where there is no consideration) then the excess is additionally to be treated as income of the transferor.
The market value rule is likely to apply only where it is clear that the transaction is either not at arm바카라 사이트™s length or where the transaction has been structured to make it appear that there is less 바카라 사이트˜consideration바카라 사이트™ than the value actually given for the right to relevant receipts.