LLPs and intangibles: avoiding traps in M&A and intra-group transfers

Intra-group transfers of intangible fixed assets (IFAs) to or from LLPs are increasingly common as precursors to M&A transactions or post-acquisition tidy-ups. Unfortunately, the tax treatment of such transfers seems confused and makes tax neutral reorganisations involving IFAs materially harder to achieve than those involving chargeable gains assets.