{
  "url": "https://openlegislation.uk/corporation-tax-act-2009/section-775",
  "json_url": "https://openlegislation.uk/corporation-tax-act-2009/section-775.json",
  "legislation": "ukpga/2009/4",
  "legislation_title": "Corporation Tax Act 2009",
  "legislation_url": "https://openlegislation.uk/corporation-tax-act-2009",
  "path": "section/775",
  "kind": "section",
  "number": "775",
  "heading": "Transfers within a group",
  "text": "(1) A transfer of an intangible fixed asset from one company (“the transferor”) to another company (“the transferee”) is tax-neutral for the purposes of this Part if—\n(a) at the time of the transfer both companies are members of the same group,\n(b) immediately before the transfer the asset is a chargeable intangible asset in relation to the transferor, and\n(c) immediately after the transfer the asset is a chargeable intangible asset in relation to the transferee.\n(2) For the consequences of a transfer being tax-neutral for the purposes of this Part, see section 776.\n(3) Part 4 of TIOPA 2010 (provision not at arm's length) does not apply in relation to a transfer to which subsection (1) applies.\n(4) Subsection (1) does not apply if—\n(a) the transferor or transferee is a qualifying society within the meaning of section 461A of ICTA (incorporated friendly societies entitled to exemption from tax), ...\n(b) the transferee is a dual resident investing company within the meaning of section 949 of CTA 2010 (dual resident investing companies) , or\n(c) an election under section 18A has effect in relation to the transferor and the asset has at any time been held by the transferor wholly or partly for the purposes of a permanent establishment in a territory outside the United Kingdom through which the transferor carries on business.",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "Words in s. 775(3) substituted (with effect in accordance with s. 381(1) of the amending Act) by Taxation (International and Other Provisions) Act 2010 (c. 8), s. 381(1), Sch. 8 para. 146 (with Sch. 9 paras. 1-9, 22)"
    },
    {
      "type": "F",
      "label": "F2",
      "text": "Word in s. 775(4)(a) omitted (19.7.2011) by virtue of Finance Act 2011 (c. 11), Sch. 13 paras. 5, 31"
    },
    {
      "type": "F",
      "label": "F3",
      "text": "Words in s. 775(4)(b) substituted (with effect in accordance with s. 1184(1) of the amending Act) by Corporation Tax Act 2010 (c. 4), s. 1184(1), Sch. 1 para. 648 (with Sch. 2)"
    },
    {
      "type": "F",
      "label": "F4",
      "text": "S. 775(4)(c) and word inserted (19.7.2011) by Finance Act 2011 (c. 11), Sch. 13 paras. 5, 31"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2009/4/section/775",
    "retrieved_at": "2026-10-29T09:11:19.560467+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}