CA50820 - MEA: Group transfers: interest granted to transferor
Where, in an intra-group transfer, the asset acquired by the transferee is an interestor right granted by the transferor, CAA01/S412 (2) provides that the restriction is to be applied by reference to a just apportionment of the transferor’s expenditure.
An example of this is leasehold granted out of a freehold interest.