775Transfers within a groupU.K.
(1)A transfer of an intangible fixed asset from one company (“the transferor”) to another company (“the transferee”) is tax-neutral for the purposes of this Part if—
(a)at the time of the transfer both companies are members of the same group,
(b)immediately before the transfer the asset is a chargeable intangible asset in relation to the transferor, and
(c)immediately after the transfer the asset is a chargeable intangible asset in relation to the transferee.
(2)For the consequences of a transfer being tax-neutral for the purposes of this Part, see section 776.
(3)Schedule 28AA to ICTA (provision not at arm's length) does not apply in relation to a transfer to which subsection (1) applies.
(4)Subsection (1) does not apply if—
(a)the transferor or transferee is a qualifying society within the meaning of section 461A of ICTA (incorporated friendly societies entitled to exemption from tax), or
(b)the transferee is a dual resident investing company within the meaning of section 404 of that Act (limitation of group relief).