Intangible fixed assets transactions between related parties
Produced in partnership with Anne Fairpo of Temple Tax Chambers
Intangible fixed assets transactions between related parties

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

  • Intangible fixed assets transactions between related parties
  • Who is a related party?
  • Participator or associate
  • Control
  • Major interest
  • Rights and powers
  • Connected
  • Related party transactions
  • Market value
  • Royalties
  • More...

STOP PRESS relating to pre-1 April 2002 assets: The Finance Act 2020 contains provisions that allow companies to claim corporation tax relief for intangible fixed assets (IFAs) created before 1 April 2002 when acquired from related parties on or after 1 July 2020 (subject to transitional provisions to preserve the rules for such IFAs held immediately before 1 July 2020 and specific anti-avoidance provisions). A new regime also applies to fungible assets from this date. For more, see News Analyses: Finance Bill 2020—Reform of tax treatment of pre-Finance Act 2002 intangible fixed assets and Spring Budget 2020—Tax analysis—Intangibles reform.

This Practice Note considers the tax treatment of transactions in intangible assets between related parties within the corporate intangible fixed assets regime (IFA regime). It does not cover transfers between group companies, for which see Practice Note: Transfers within an intangible fixed assets group and degrouping charges.

Related parties are generally those who share economic interests with a company within the IFA regime. Transactions between the company and related parties are subject to specific rules intended to prevent opportunities for tax advantages to be obtained which are not intended by the legislation.

Note that the definition of a ‘related party’ is not the same as the definition of a ‘connected person’, which is used extensively in tax legislation. This is because the IFA regime only relates to corporation

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