2(1)For the purposes of corporation tax on chargeable gains, the disposal of property, rights or liabilities which is constituted by a preparatory transfer shall, subject to the following provisions of this Schedule, be taken in relation to both—U.K.
(a)the person to whom the disposal is made, and
(b)the person making the disposal,
to be effected for a consideration such that no gain or loss accrues to the person making the disposal.
(2)Section 171(1) of the Gains Act (which makes provision in relation to the disposal of assets from one member of a group of companies to another member of the group) shall not apply where the disposal in question is a preparatory transfer.