CTM15310 | Distributions: general: transfers between companies within the charge to CT
From HM Revenue & Customs · Company Taxation Manual
Where an asset is transferred from one company to another, any material difference between the market value and the consideration given should be treated as a distribution within CTA10/S1000 (1) B or (1) G as appropriate (unless for distributions made before 17 July 2012 CTA10/S1002 or S1021 applies, see CTM15300). This is irrespective of the other tax consequences of the transfer for either company.