Corporation Tax Act 2009 section 776

Meaning of "tax-neutral" transfer

Section 776 defines what it means for a transfer of an asset to be "tax-neutral" for the purposes of the intangible fixed assets regime, and sets out the consequences that follow from such a transfer.

• A tax-neutral transfer is treated as though the transferor has not realised the asset and the transferee has not acquired it
• The transferee steps into the shoes of the transferor, being treated as having held the asset at all times the transferor held it and as having done everything the transferor did in relation to it
• The original cost of the asset recognised for tax purposes in the hands of the transferor carries over to the transferee at the same amount
• All credits and debits previously brought into account for tax purposes by the transferor are treated as if they had been brought into account by the transferee