Transfers of value between connected companies

Transactions between connected persons involving derivative contracts are covered by TIOPA10/Part 4 (transfer pricing) – see CFM56050.

CTA09/S695 deals with the following situation (where Part 4 might not apply):

There is a transfer of value as a result of the abandonment of a valuable option

the transfer is between connected companies (A and B), and

the transferee company (B) is not chargeable to tax under CTA09/PART7 in respect of the option.

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