Part 12 Chargeable Gains

Part 12 Chargeable Gains

Transferred tax history is not to be regarded as an asset

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Where the seller and the purchaser jointly make a TTH election in respect of the TTH asset, the transfer of tax history is not to be treated as—

(a)     the disposal or acquisition of an asset for the purposes of TCGA 1992, or

(b)     the disposal or acquisition of an intangible fixed asset for the purposes of Part 8 of CTA 2009.

Consideration for transferred tax history to be treated as consideration for the licence interest

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The amount or value of any consideration for the

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