Related Commentary  Related HMRC Manuals

21(1)  In section 844 of CTA 2009 (overview of Chapter 13 of Part 8: transactions between related parties) after subsection (2) insert–

844(2ZA)  “Sections 849AB to 849AD make provision for the grant of a licence or other right by a company to a related party, or vice versa, to be treated as being at market value.”

21(2)  After section 849A of that Act insert–

“GRANTS TREATED AS BEING AT MARKET VALUE

849AB  Grant of licence or other right treated as at market value

849AB(1)  This section applies if–

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