This provision is concerned with situations where the transferor company of an intangible asset is within the CG rules for corporation tax in respect of a disposal and that disposal is regarded for CG purposes as taking place on no gain/no loss terms.

Normally in these circumstances the asset will also be outside CTA09/PART8 in the hands of the transferee company by virtue of the exclusion of assets acquired from companies that are ‘related parties’ of the transferee. (See CIRD11520 for the exclusion and CIRD45105 onwards for the meaning of ‘related party’).

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