Corporation Tax Act 2009 section 100

Transactions between related parties

Section 100 provides transitional rules for how the related party provisions in the intangible fixed assets regime apply across key changeover dates, particularly 12 March 2008 and 16 March 2005.

• Where an accounting period straddles 12 March 2008 and ends after 31 March 2009, it is split into two notional periods at that date for the purpose of applying the expanded related party definition in section 835(7) to (9), which only affects credits and debits in the later portion.
• Section 835(7) to (9) cannot be used to retrospectively classify a party as a related party for any time before 12 March 2008.
• For the market value transfer rules in sections 845 to 849, the expanded related party definition in section 835(7) to (9) only applies to asset transfers made on or after 12 March 2008, and for transfers made before 16 March 2005, a narrower version of the related party definition applies (with section 835(5)(b) omitted).
• The rules on transfers involving other taxes (section 847) and transfers involving gifts of business assets (section 849) do not apply at all to any transfer of assets made before 16 March 2005.