½Û×ÓÊÓƵ

Where the qualifying conditions are met, then subject to the exceptions listed at D2.314, all intra-group transfers of capital assets are deemed to take place not at market value or for the actual sale price, but for a consideration that gives rise to neither a gain nor loss to the transferor company¹.

The conditions for intra-group transfers of assets to be treated as no gain, no loss disposals are that:

1. Ìý

   (a)ÌýÌýÌýÌý the transferor company is UK resident at the time of disposal, or the asset is a 'chargeable asset' in the hands of the transferor immediately before the transfer, and

2. Ìý

   (b)ÌýÌýÌýÌý the transferee company is UK resident at the time of disposal, or the asset is a 'chargeable asset' in the hands of the transferee immediately after the transfer

For (a) and (b) above, an asset is a 'chargeable asset' in the hands of a company at a particular time if, on a disposal by the company at that time, any gain would be a chargeable gain and