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HMRC internal manual

Company Taxation Manual

Distributions: general: transfers between companies within the charge to CT

Where an asset is transferred from one company to another, any material difference between the market value and the consideration given should be treated as a distribution within CTA10/S1000(1) B or G as appropriate (unless for distributions made before 17 July 2012 CTA 2010/S1002 or 1021 applies, see CTM15300.) This is irrespective of the other tax consequences of the transfer for either company.