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Where an intangible fixed asset is transferred between two companies which are members of the same group, and the asset is a chargeable intangible asset for both companies at the time of the transfer, the transfer is treated as tax neutral¹. This provides similar relief to the capital gains provisions see D2.310.

A 'chargeable intangible asset' is broadly one which falls within the computational rules of the corporate intangible regime² (for detailed definition see D1.635).

Tax neutrality has the following main tax implications³:

1. Ìý

   •ÌýÌýÌýÌý the transfer is not regarded as a realisation by the transferor nor as an acquisition by the transferee (this means, in particular, that the transferee inherits the transferor's tax cost of the asset), and

2. Ìý

   •ÌýÌýÌýÌý the transferee inherits the transferor's tax history, and is regarded as if it had itself owned the asset throughout the period it was owned by the transferor; all debits and credits brought into account by the transferor are brought into account by the transferee; this means, in particular,