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HMRC internal manual

Corporate Intangibles Research and Development Manual

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Intangible assets: avoidance: measures in F2A05: change to rules: market value rules

Market value rules

This page deals with the changes to the market value rules. Changes to the related party rules are dealt with at CIRD48270.

Amendments to the market value rule on transfers between related parties were made in respect of transfers:

  • at over or under value (CIRD45033) to ensure that the legislation for employment income and distributions could still act,
  • where CG gift relief was claimed (CIRD45035) so that the gain deferred reduced the expenditure recognised for the purposes of FA02/SCH29 and CTA09/PART8.