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HMRC internal manual

Capital Allowances Manual

MEA: Group transfers: interest granted to transferor

Where, in an intra-group transfer, the asset acquired by the transferee is an interestor right granted by the transferor, CAA01/S412 (2) provides that the restriction is to be applied by reference to a just apportionment of the transferor’s expenditure.

An example of this is leasehold granted out of a freehold interest.