Corporation Tax Act 2009 section 826

Amalgamation of, or transfer of engagements by, certain societies

Section 826 provides that the transfer of intangible fixed assets between certain types of society is treated as tax-neutral when it occurs as part of an amalgamation or a transfer of engagements between those societies.

• When two or more qualifying societies amalgamate, or one transfers its engagements to another, any intangible fixed assets transferred as part of that process are treated as tax-neutral — meaning no taxable gain or allowable loss arises on the transfer.
• The assets must be chargeable intangible assets in the hands of both the transferring society immediately before the transfer and the receiving society immediately after it.
• The types of society covered are building societies, registered societies, and co-operative associations that qualify as UK agricultural or fishing co-operatives.
• This ensures that restructurings within the mutual and co-operative sector are not hindered by a corporation tax charge on the movement of intangible fixed assets between the societies involved.