Related Commentary  Related HMRC Manuals

753(1)  The relevant amount (see subsection (2)) is to be treated as income of the transferor chargeable to corporation tax in the same way and to the same extent as that in which the relevant receipts–

(a)would have been chargeable to corporation tax, or

(b)would have been brought into account in calculating any profits for the purposes of corporation tax,

but for the transfer of the right to relevant receipts.

753(2)  The relevant amount is–

(a)(except where paragraph (b) applies) the amount of the consideration for the transfer of the right, or

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