845 Transfer between company and related party treated as at market value

Transfers treated as being at market value

845  Transfer between company and related party treated as at market value

(1)     The basic rule is that a transfer of an intangible asset—

(a)     from a company to a related party, or

(b)     to a company from a related party,

is treated for all purposes of the Taxes Acts as being at market value (as respects both the company and the related party) if condition A or B is met.

(2)     Condition A is that the asset is a chargeable intangible asset in relation to the transferor immediately before the transfer.

(3)     Condition B is that

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