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Corporate intangible regime and relevance of related party

The concept of related party is important in the corporate intangible regime in several areas as follows:

1. Ìý

   •ÌýÌýÌýÌý whether the intangible is within the corporate intangible regime, see D1.601A

2. Ìý

   •ÌýÌýÌýÌý if the intangible is goodwill or certain customer-related assets then depending on the date of acquisition or creation there are restrictions on the tax relief if the goodwill was acquired from a related party, see the summary in D1.629A

3. Ìý

   •ÌýÌýÌýÌý rollover relief on realisation of intangibles and reinvestment, see D1.635

4. Ìý

   •ÌýÌýÌýÌý whether the market value rule applies on transfers, see D1.611A

5. Ìý

   •ÌýÌýÌýÌý royalty payments (see below)

The definition of related party is determined by:

1. Ìý

   •ÌýÌýÌýÌý whether there is control or a major interest between the parties

2. Ìý

   •ÌýÌýÌýÌý taking into account all the rights and powers of the related parties, and

3. Ìý

   •ÌýÌýÌýÌý all the rights and powers of persons connected to the related parties

these concepts are detailed further below.

Royalties