CIRD40300 - Intangible assets: groups: tax-neutral transfers: effect

CTA09/PART8/S776

Where a transfer is to be treated as one on 바카라 사이트˜tax-neutral바카라 사이트™ terms, the transfer is regarded for this purpose as not involving any realisation of the asset by the transferor, nor any acquisition by the transferee.

There is then a 바카라 사이트˜stand in shoes바카라 사이트™ approach such that the transferee is treated as having held the asset throughout, and having done all the things in relation to the asset as were in fact done by the transferor.

In particular, this means

  • the transferee inherits the transferor바카라 사이트™s tax cost for the asset (see CIRD12720), and
  • all such debits and credits as have been brought into account under CTA09/PART8 by the transferor are treated for this purpose as though they had been brought into account by the transferee, and
  • the asset continues to be treated in the hands of the transferee as it was in the hands of the transferor. For instance, the goodwill restriction in s816A will not take effect even though the transfer took place after 8 July 2015 unless that restriction already applied to the transferor.

Note

A 바카라 사이트˜tax-neutral바카라 사이트™ transfer is therefore a different mechanism to a No Gain/No Loss transfer. Although both are commonly referred to as 바카라 사이트˜tax-free바카라 사이트™ transfers they should not be confused with one another.