Part 3Trading income

Chapter 13Disposal and acquisition of know-how

179Seller controlled by buyer etc

1

This section applies if a disposal of know-how is by way of sale and—

a

the seller is a body of persons over which the buyer has control,

b

the buyer is a body of persons over which the seller has control, or

c

both the seller and the buyer are bodies of persons and another person has control over both of them.

2

In such a case—

a

section 177 does not apply, and

b

no election may be made under section 178.

3

For the purposes of this section “body of persons” includes a firm.