2075.This section allows the transfer of intangible fixed assets on a tax-neutral basis between group members. It is based on paragraph 55 of Schedule 29 to FA 2002.
2076.Without this rule, intra-group transfers, being transactions between related parties, would be regarded as taking place at market value (under section 845) and would trigger the normal realisation rules.
Commentary on Sections Overview Chapter 9: Application of this Part to groups of companies Section 775: Transfers within a group