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Contents

Official guidance
Corporate Intangibles Research and Development Manual

CIRD48000 · Intangible assets: avoidance

  • CIRD48010 · Introduction
  • CIRD48020 · Structural defences and their limitations
  • CIRD48030 · Specific rules
  • CIRD48040 · More general CT rules
  • CIRD48050 · Change of ownership of company
  • CIRD48105 · Tax-driven transactions: approach to take
  • CIRD48110 · Tax-driven transactions: outline of provision
  • CIRD48120 · Tax-driven transactions: relationship of anti-avoidance rule with other provisions
  • CIRD48130 · Tax-driven transactions: whether tax avoidance main object
  • CIRD48140 · Tax-driven transactions: circumstances where anti-avoidance rule may be in point
  • CIRD48150 · Tax-driven transactions: nature of counteraction
  • CIRD48200 · Measures in FA03/S184: background
  • CIRD48230 · Measures in FA03/S184: how they work
  • CIRD48250 · Measures in FA03/S184: position for accounting periods ending at different times
  • CIRD48260 · Measures in F2A05: change to rules: market value rules
  • CIRD48270 · Measures in F2A05/S41: change to rules: related party rules
  • CIRD48280 · New measures in FA06/S77: change to rules: new assets derived from companies’ pre-FA 2002 assets
  • CIRD48290 · New measures in FA09/S70: confirmation of rules: time of creation of goodwill and certain other internally generated assets
  • CIRD48300 · New measures in FA11/S62: confirmation of rules: goodwill and intangible assets relating to an oil & gas licence excluded
  • CIRD48320 · Intangible assets exchanged for other assets recognised at net book value (step-up schemes)
  • CIRD48330 · Measure in F(2)A15/S42: accounting step-up schemes involving transfers before 1 January 2026
  • CIRD48340 · FA18/S20: intangible asset realisation involving non-monetary receipts
  • CIRD48350 · Related party licence not granted at market value between 22 November 2017 and 31 December 2025 - interaction with transfer pricing
  • CIRD48360 · Related party licence examples
  1. Intangible assets: avoidance: contents
  2. Intangible assets: avoidance: measures in F2A05: change to rules: market value rules

CIRD48260 | Intangible assets: avoidance: measures in F2A05: change to rules: market value rules

From HM Revenue & Customs · Corporate Intangibles Research and Development Manual

Market value rules

This page deals with the changes to the market value rules. Changes to the related party rules are dealt with at CIRD48270.

Amendments to the market value rule on transfers between related parties were made in respect of transfers:

  • at over or under value (CIRD45033) to ensure that the legislation for employment income and distributions could still act,

  • where CG gift relief was claimed (CIRD45035) so that the gain deferred reduced the expenditure recognised for the purposes of FA02/SCH29 and CTA09/PART8.

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