Corporation Tax Act 2009 section 824

Transfer of business of building society to company

Section 824 provides for tax-neutral treatment of intangible fixed assets when a building society transfers its entire business to a successor company under the Building Societies Act 1986.

• Applies when a building society transfers its whole business to a company under section 97 of the Building Societies Act 1986 and the transfer includes intangible fixed assets
• The intangible fixed assets must be chargeable intangible assets for both the building society immediately before the transfer and the successor company immediately after the transfer
• Where these conditions are met, the transfer of those intangible fixed assets is treated as tax-neutral for corporation tax purposes under Part 8 of the Corporation Tax Act 2009
• Further rules in section 825 address how the degrouping charge and principal company provisions (sections 780 and 785) apply in these circumstances