Corporation Tax Act 2009 section 774

Overview of Chapter

Section 774 introduces Chapter 9, which sets out the special rules governing how the intangible fixed assets regime applies to transactions involving companies within the same group.

• Transfers of intangible fixed assets between companies in the same group can qualify as "tax-neutral transfers", meaning no immediate tax charge arises on the transaction.
• Roll-over relief (deferring a gain when proceeds are reinvested in new intangible assets) can be applied across group members, so one company's reinvestment can satisfy another company's disposal.
• When a company leaves a group, it is treated as having sold and immediately reacquired any intangible fixed assets it received from other group members at market value, potentially triggering a "degrouping charge" — though the group can elect for a different group member to bear that charge, and roll-over relief may apply.
• Certain payments made between group members in connection with roll-over relief claims or degrouping elections are disregarded for tax purposes.