Related Commentary  Related HMRC Manuals

820(1)  If the transfer of business includes intangible fixed assets that–

(a)are chargeable intangible assets in relation to the transferor immediately before the transfer, and

(b)are chargeable intangible assets in relation to the transferee immediately after the transfer,

the transfer of those assets is tax-neutral for the purposes of this Part.

820(2)  This section applies only if the transfer of the business or part meets the genuine commercial transaction requirement (see section 831).

820(3)  This section does not apply if the transferor is a transparent entity.

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