CTM15310 - Distributions: general: transfers between companies within the charge to CT

Where an asset is transferred from one company to another, any material difference between the market value and the consideration given should be treated as a distribution within ICTA88/S209 (4) or ICTA88/S209 (2)(b) as appropriate unless ICTA88/S209 (5) or ICTA88/S209 (6) applies see CTM15300. This is irrespective of the other tax consequences of the transfer for either company.