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HMRC internal manual

Corporate Intangibles Research and Development Manual

Intangible assets: groups: tax-neutral transfers: effect


Where a transfer is to be treated as one on ‘tax-neutral’ terms, the transfer is regarded for this purpose as not involving any realisation of the asset by the transferor, nor any acquisition by the transferee.

There is then a ‘stand in shoes’ approach such that the transferee is treated as having held the asset throughout, and having done all the things in relation to the asset as were in fact done by the transferor.

In particular, this means the transferor inherits the transferor’s tax cost for the asset (see CIRD12720), and all such debits and credits as have been brought into account under CTA09/PART8 by the transferor are treated for this purpose as though they had been brought into account by the transferee.