Transfers within a group
55(1)Where—
(a)an intangible fixed asset is transferred from one company (“the transferor”) to another company (“the transferee”) at a time when both companies are members of the same group, and
(b)the asset is a chargeable intangible asset in relation to the transferor immediately before the transfer and in relation to the transferee immediately after the transfer,
the transfer of the asset is treated for the purposes of this Schedule as tax-neutral (see paragraph 140).
(2)Sub-paragraph (1) does not apply—
(a)if the transferor or transferee is a qualifying society within the meaning of section 461A of the Taxes Act 1988 (incorporated friendly societies entitled to exemption from tax), or
(b)if the transferee is a dual resident investing company within the meaning of section 404 of that Act (limitation of group relief).