Rules are in place to ensure that receipts which would be taxable as income on the transferor continue to be taxable as such following a transfer of the rights to those receipts only.

Where a company within the charge to corporation tax transfers a right to relevant receipts to another person, but does not also transfer the asset from which the right arises, the charge to corporation tax on income applies to the relevant amount unless an exclusion applies.

The relevant amount is either:

the amount received for the transfer of the right; or

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