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Intercompany transfer of internally generated goodwill


My client company has transferred to a wholly owned subsidiary a business which commenced in 2006 and was until the transfer carried on as a division of my client’s existing and continuing trade. The internally generated goodwill of the business has been transferred to the subsidiary for market value. It is accepted that this goodwill falls within the intangible assets regime of CTA 2009 Part 8. How is this intercompany transfer treated for tax purposes?


It is assumed that the internally generated goodwill or intellectual property was created after 1 April 2002 and that both companies are UK incorporated and resident. It is also assumed that the companies form part of the same 75% group for corporation...

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