Article 42 - Intra-Group Transfer of Assets
(1) Where a
Company ("Company A") disposes of an asset to another Company ("Company B") at a time when both Companies are QFC Entities and are members of the same Group, then Company A and Company B shall be treated for the purposes of these Regulations as if the asset was acquired by Company B for a consideration of such amount as would secure that neither a gain nor a loss would accrue to Company A on the disposal.
(2) If within 12 months after the disposal in Article 42(1) Company A and Company B cease to be members of the same
Group then that disposal will be treated as having taken place at Market Value, at the date of the disposal.