Excluded intangible fixed assets
Produced in partnership with Anne Fairpo of Temple Tax Chambers
Excluded intangible fixed assets

The following Tax practice note Produced in partnership with Anne Fairpo of Temple Tax Chambers provides comprehensive and up to date legal information covering:

  • Excluded intangible fixed assets
  • Assets wholly excluded
  • Assets excluded except as to royalties
  • Assets excluded to a specified extent
  • Partial exclusion

Certain intangible fixed assets are excluded from the intangible fixed assets regime (IFA regime).

Where an asset is excluded, either in whole or in part, options and similar rights to acquire or dispose of the asset are also excluded from IFA regime.

Gains and losses relating to an intangible fixed asset excluded from the IFA regime, are dealt with under the normal corporation tax (or income tax) rules (for which, see: Capital gains and businesses—overview) unless other specific rules apply. In some cases the asset is excluded so that a different set of specific rules can be applied (eg for companies, qualifying research and development expenditure is excluded from the IFA regime in order that the research and development tax relief rules can be applied instead, for which see: R&D tax relief—overview).

There are three types of excluded assets from the IFA regime:

  1. assets wholly excluded

  2. assets excluded except as respects royalties (at most the intangible fixed asset rules only change the timing of a deduction for royalties), and

  3. assets excluded to a specified extent

Assets wholly excluded

The following assets are entirely excluded from the IFA regime, even if they are within the definition of an intangible fixed asset for accounting purposes:

  1. assets held for non-commercial purposes

  2. rights over tangible assets (eg contractual rights in respect of an interest in land, or in moveable property)

  3. financial assets, including

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