Corporation Tax Act 2009 section 964

Transfers of assets etc. treated as payments

Section 964 explains how transfers of assets, appropriations of assets by personal representatives, and the set-off or release of debts are treated as payments for the purposes of the rules on estates in administration.

• A transfer or appropriation of assets is treated as a payment equal to the assets' value at the date of transfer or appropriation
• The set-off or release of a debt is treated as a payment equal to the amount of the debt
• If at the end of the administration period there is an outstanding obligation to transfer assets or an entitlement to appropriate them, those assets are treated as payable at their value at that time
• If at the end of the administration period there is an outstanding obligation or entitlement to release or set off a debt, a sum equal to that debt is treated as payable at that time