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Sure, I just need a viewpoint on the following:
Currently have a Joint venture with another company. We jointly develop and sell some software. To allow for better growth, branding etc, we just want to create a new company and use that in future. We currently share profits etc 50/50 and would have a 50/50 ownership in the new company. The question is whether we can simply transfer the IPR of the software (which we technically own 50/50) into the new company without any tax implications. We're not selling anything, we're keeping the same ownership effectively and there are no patents or registered rights. Just seeking a second opinion on whether this is likely to be relatively straightforward to do.
Thank you John,What you are proposing to do is known as an "intra group transfer" which would be tax neutral.
You may see here for further information:
http://taxnotes.co.uk/corporate-tax/corporate-tax-groups-intra-group-transfers-are-tax-neutral/May I help further?