Corporation Tax Act 2009 section 817

Overview of Chapter

Section 817 introduces Chapter 11, which deals with the tax treatment of intangible fixed assets when they are transferred as part of a business or trade transfer.

• Certain transfers of intangible fixed assets can be treated as tax-neutral, meaning no immediate tax charge arises on the transfer
• Relief may also be available where intangible fixed assets are transferred to a non-UK resident company
• A genuine commercial transaction requirement applies to some of these reliefs, ensuring they cannot be used for tax avoidance purposes
• The chapter covers various reorganisation scenarios including company reconstructions, cross-border mergers, building society transfers, and society amalgamations