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HMRC internal manual

Corporate Intangibles Research and Development Manual

HM Revenue & Customs
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Patent Box: relevant IP losses: transfer of a trade between group members


Where a company:

  • has a set-off amount in relation to a trade of the company for an accounting period,
  • is a member of a group, and
  • ceases to carry on the trade,

then where another company (‘the transferee’) that is a member of the group begins to carry on that trade, then an amount equal to the set-off amount is to become, or be added to, the set-off amount in relation to the trade of the transferee for the accounting period in which the transferee begins to carry on the trade.