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Corporation Tax Act 2009

Section 845: Transfer between company and related party treated as at market value

2177.This section gives the main related party, market value rule. It is based on paragraph 92 of Schedule 29 to FA 2002.

2178.Paragraph 92 of Schedule 29 to FA 2002 also sets out the exceptions to the basic rule. When the intangible fixed assets rules were first introduced there were only two exceptions. But, subsequently, further exceptions were added and the paragraph grew in both length and complexity with little commonality in the substance of the exceptions. It is therefore rewritten in five sections in this Act, the first stating the basic market value rule and the four immediately following stating the exceptions.

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