The following Tax practice note Produced in partnership with Anne Fairpo of Temple Tax Chambers provides comprehensive and up to date legal information covering:
The intangible fixed assets regime (IFA regime) has a principal anti-avoidance rule which applies to tax avoidance arrangements, which is explained further below.
In addition to this principal anti-avoidance rule, there are a number of specific anti-avoidance rules, intended to counter various methods of exploiting the legislation:
cessation of UK residence (ie the deemed market value disposal rule)
loss-buying of non-trade intangible fixed assets
fungible assets realisation and reacquisition rules
These rules are explained further in this Practice Note. Further specific rules also apply counter avoidance, which relate to:
degrouping adjustments, for which, see Practice Note: Transfers within an intangible fixed assets group and degrouping charges—Degrouping charges
business reorganisations which should be tax neutral, subject to a commercial purpose test, for which see Practice Note: Intangible fixed assets on the transfer of a trade
certain related party acquisitions occurring on or after 1 July 2020
transfers between related parties (ie the deemed market value transaction rule), for which, see Practice Note: Intangible fixed assets transactions between related parties, and
timing rules on creation of goodwill
Note that wider corporation tax anti-avoidance rules will also apply to intangible assets where applicable, such as:
transfer pricing, see Practice Note: What is transfer pricing?
controlled foreign companies, see: CFC rules—overview
transfer of deductions, see Practice Note: Group relief—types of losses that can be surrendered—Finance Act 2013 targeted anti-avoidance rules
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