Commentary

D1.661 Intangible assets—company reconstruction involving transfer of business

Corporate tax
Corporate tax | Commentary

D1.661 Intangible assets—company reconstruction involving transfer of business

Corporate tax | Commentary

D1.661 Intangible assets—company reconstruction involving transfer of business

Where there is a company reconstruction involving the transfer of a business, any intangible fixed assets included in the transfer are treated as transferred on a tax neutral basis1. The implications of a tax neutral transfer are the same as for an intra-group transfer2 (see D1.646). Where a transfer qualifies both as part of a reconstruction and a transfer within a group of companies, the intra-group transfer rules take priority3.

A company reconstruction involves a 'scheme of reconstruction', which has the same meaning as for capital gains purposes (see D6.450). A scheme of

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