3U.K.In paragraphs 4 to 6—
a “relevant transfer” means a transfer of any property, rights or liabilities by or under a transfer scheme under section 8, and
“transferor” and “transferee” have the same meaning as in Schedule 1.
Commencement Information
I1Sch. 2 para. 3 in force at 1.10.2011 by S.I. 2011/2329, art. 3
4U.K.For the purposes of the Taxation of Chargeable Gains Act 1992 a disposal constituted by a relevant transfer is to be treated in relation to the transferor and transferee as made for a consideration such that no gain or loss accrues to the transferor.
Commencement Information
I2Sch. 2 para. 4 in force at 1.10.2011 by S.I. 2011/2329, art. 3
5U.K.For the purposes of Chapter 4 of Part 5 of the Corporation Tax Act 2009 (loan relationships: continuity of treatment on transfers within groups or on reorganisations) the transferor and transferee are to be treated in relation to a relevant transfer as if, for the purposes of the transfer, they were members of the same group.
Commencement Information
I3Sch. 2 para. 5 in force at 1.10.2011 by S.I. 2011/2329, art. 3
6(1)For the purposes of Part 8 of the Corporation Tax Act 2009 (intangible fixed assets) a relevant transfer of a chargeable intangible asset is to be treated as tax-neutral.U.K.
(2)Part 4 of the Taxation (International and Other Provisions) Act 2010 (transfer pricing) does not apply in relation to a transfer to which sub-paragraph (1) applies.
(3)For the purposes of section 882 of the Corporation Tax Act 2009 (application of Part 8 to assets created or acquired on or after 1 April 2002) assets acquired by a transferee on a relevant transfer are to be treated as if they were acquired from a person who at the time of the acquisition was a related party.
Commencement Information
I4Sch. 2 para. 6 in force at 1.10.2011 by S.I. 2011/2329, art. 3