Intangible fixed assets

Copyright © 2025 LexisNexis

Intangible fixed assets regime (IFA regime)

The IFA regime, contained in Part 8 of the Corporation Tax Act 2009, was introduced in 2002 for the purposes of taxing companies in respect of their intangible fixed assets, which are broadly intellectual property (IP) and goodwill.

For more details, see Practice Notes: What is an intangible fixed asset? and Excluded intangible fixed assets.

The IFA regime aims to tax and relieve profits and losses in respect of intangible assets as income, generally in accordance with accounting principles.

The IFA regime provides more opportunities for corporation tax relief than was previously the case. For more details, see Practice Note: How intangible fixed assets are taxed—basic principles and Intangible fixed assets—anti-avoidance.

Tax treatment of intangible assets outside the IFA regime

Before the introduction of the IFA regime, companies were subject to corporation tax in respect of intangible assets on the basis of general tax principles (largely enshrined in case law) that still apply for individuals. Broadly, outside of the IFA regime, acquisitions and disposals of IP (other than patents) held otherwise than as trading stock are

To view the latest version of this document and thousands of others like it, sign-in with LexisNexis or register for a free trial.

Existing user? Sign-in TAKE A FREE TRIAL
Powered by Lexis+®
Latest Tax News

Tax weekly highlights—4 September 2025

This week's edition of Tax weekly highlights includes: (1) 26 November 2025 announced as Budget date, (2) News Analysis articles published on FTT decisions in Lexgreen Services and Tinkler, and (3) new HMRC guidance published on reserved investor fund notifications.

Preliminary decision of FTT finds closure notices had wide scope allowing HMRC to raise alternative arguments in the substantive litigation (Tinkler v HMRC)

Tax analysis: In Tinkler v HMRC, the First-tier Tax Tribunal (FTT) in a preliminary decision considered the taxpayer’s application for it to decide that HMRC was prevented by the scope of its closure notices from raising two alternative arguments in the appeal. The FTT decided in favour of HMRC in relation to both arguments.

FTT considers the meaning of life (Lexgreen Services Ltd v HMRC)

Tax analysis: In Lexgreen Services Ltd v HMRC, the First-tier Tax Tribunal (FTT) held that a company can be liable for inheritance tax under section 201(1)(d) of the Inheritance Tax Act 1984 (IHTA 1984) if that company is a ‘live company’ at the time of the relevant transfer.

Tax weekly highlights—28 August 2025

This week's edition of Tax weekly highlights includes: (1) Agent Update: Issue 134 and (2) News Analysis on the FTT’s decision in John Jones Civil Engineering & Groundworks Ltd v HMRC.

View Tax by content type :  
News
Practice notes
Precedents
Q&As

Popular documents

Priority between loss reliefs in loss making companies

Priority between loss reliefs in loss making companiesWhy does it matter?A company that is a member of a group and has incurred any of the types of losses available for surrender by way of group relief may, without any further rules, have more than one way in which to use the loss. There are a

Taxation of derivatives—chargeable gains basis rules

Taxation of derivatives—chargeable gains basis rulesThe general rule, as explained in Practice Note: Taxation of derivatives—the main rules, is that the profits and losses arising to a company from its derivative contracts are (like the profits and losses from its loan relationships) brought into

What are capital allowances and capital expenditure?

What are capital allowances and capital expenditure?What are capital allowances?Capital allowances are the means by which tax relief is given for some (but not all) capital expenditure. They are effectively a standardised tax-deductible version of depreciation or amortisation broadly intended to

Qualifying charitable donations and excess management expenses

Qualifying charitable donations and excess management expensesAll companies within the charge to corporation tax can deduct qualifying charitable donations (QCDs) from their total profits, after all other deductions have been made (other than group relief and group relief for carried-forward losses)
Priority between loss reliefs in loss making companies

Priority between loss reliefs in loss making companies

Priority between loss reliefs in loss making companiesWhy does it matter?A company that is a member of a group and has incurred any of the types of losses available for surrender by way of group relief may, without any further rules, have more than one way in which to use the loss. There are a

Taxation of derivatives—chargeable gains basis rules

Taxation of derivatives—chargeable gains basis rules

Taxation of derivatives—chargeable gains basis rulesThe general rule, as explained in Practice Note: Taxation of derivatives—the main rules, is that the profits and losses arising to a company from its derivative contracts are (like the profits and losses from its loan relationships) brought into

What are capital allowances and capital expenditure?

What are capital allowances and capital expenditure?

What are capital allowances and capital expenditure?What are capital allowances?Capital allowances are the means by which tax relief is given for some (but not all) capital expenditure. They are effectively a standardised tax-deductible version of depreciation or amortisation broadly intended to

Qualifying charitable donations and excess management expenses

Qualifying charitable donations and excess management expenses

Qualifying charitable donations and excess management expensesAll companies within the charge to corporation tax can deduct qualifying charitable donations (QCDs) from their total profits, after all other deductions have been made (other than group relief and group relief for carried-forward losses)