CTM06795 | Corporation Tax: loss buying: assets transferred between companies: assets treated as transferred
From HM Revenue & Customs · Company Taxation Manual
and S676DA
Under and CHAPTER2D, an asset Q is treated as if it were the same as another asset P if
asset P was transferred to the company in one of the situations covered by CTA10/CHAPTER2B and CHAPTER2D, and
asset Q derives its value wholly or partly from asset P.
This means that if the company realises a gain on disposal of asset Q, the disposal may be subject to the restrictions in CTA10/CHAPTER2B and CHAPTER2D. It does not matter that asset Q was not itself transferred to the company because asset Q's value is derived from asset P.
The legislation specifies that this will apply in particular if
asset Q is a freehold,
asset P was a leasehold, and
the company, as lessee, has acquired the reversion.