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Where there is a transfer of a 'chargeable intangible asset' from a company to a related party, or vice versa, the transfer is treated for all tax purposes as taking place at market value, regardless of the actual consideration for the transfer¹.

A chargeable intangible asset is essentially an asset within the computational rules of the corporate intangible regime.

Where there is a grant of a licence or other right in respect of a chargeable intangible asset by a company to a related party, or vice versa, on or after 22 November 2017, similar market value treatment applies to the grant (other than grants made pursuant to an obligation under a contract which was unconditional before that date)². An obligation is treated as unconditional for these purposes if it could not be varied or extinguished by the exercise of a right (whether under the contract or otherwise)³.This market value rule does not apply to a restricted asset to which CTA 2009, s 900F applies (see the