The provisions detailed in D9.301A only apply where1:
- Ìý
•ÌýÌýÌýÌý a company ('the transferor') makes a transfer to a person ('the transferee') of a right to 'relevant receipts'. Relevant receipts are defined as any income that but for the transfer would be charged to corporation tax as income of the transferor or brought into account in calculating profits of the transferor for the purposes of corporation tax. The reason for referring to income that is brought into account in calculating profits is to ensure that the sale of a right to income which would be a component in the calculation of profits from a trade or other business is included as well as the sale of pure income. The words 'but for the transfer' indicate that the legislation cannot apply where the transferor remains taxable on the income. Furthermore
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