Commentary on Sections Overview Chapter 9: Application of this Part to groups of companies Section 776: Meaning of “tax-neutral” transfer
2077.This section defines a key term. It is based on paragraph 140 of Schedule 29 to FA 2002.
2078.Here and elsewhere in this Part the provisions refer to transfers that are tax-neutral rather than, as in the source legislation, transfers that are treated as tax-neutral. Since “tax-neutral” is a defined term, the abstractness of the source is not necessary.