Section 776 of CTA explains the "consequences of a transfer of an asset being “tax-neutral... as not involving... any acquisition of the asset by the transferee." This is what precludes the annual deduction from taxable profit of 6.5% of the goodwill.
However, FRS 102 requires fair value accounting for goodwill following a reconstruction. This includes impairment of goodwill, which is the accounting equivalent of amortisation. The following guidance suggests " inform clients of the consequences of depreciating this over 5/10 years and the impact on profits and distributable reserves" https://www.accountingweb.co.uk/community/industry-insights/frs-102-sect...
A reduction in distributable reserves would affect income tax position of the shareholders and so in that sense cannot be said to be tax neutral.
Should 'tax neutral' under Corporation Tax Act 2009 be construed as relating solely to corporation tax?