CTM06790 | Corporation Tax: loss buying: assets transferred between companies: transfer of asset or gain
From HM Revenue & Customs · Company Taxation Manual
and S676DA
Profits relating to a transfer of an asset or gain will fall under the restrictions at or CHAPTER2D in one of three possible sets of circumstances.
No gain/no loss transfer
This applies where
there has been a change in ownership of a company,
following the change in ownership, an asset is transferred to the company on a no gain/no loss basis under (), and
the company realises a chargeable gain on that asset within the five years following the change in ownership.
Tax-neutral transfer
This applies where
there has been a change in ownership of the company,
following the change in ownership, an intangible fixed asset is transferred to the company on a tax-neutral basis under (), and
the company realises a non-trading chargeable realisation gain on that asset within the five years following the change in ownership.
For these purposes, a non-trading chargeable realisation gain is a chargeable realisation gain which is a non-trading credit for the purposes of .
Transfer of gain
This applies where
there has been a change in ownership of the company, and
within five years of the change in ownership, a chargeable gain or part of a gain is treated as accruing to the company due to an election under ().