Where a company acquires (or otherwise incurs capitalised expenditure upon) an intangible fixed asset that falls within the corporate intangible fixed asset regime (IFA...
Produced in partnership with Anne Fairpo of Temple Tax Chambers [Letterhead] [Addressed to HMRC Inspector] [Date] We hereby jointly elect pursuant to section 792 of the...
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...
The intangible fixed asset regime Companies within the charge to corporation tax are generally subject to the intangible fixed assets regime (the IFA regime) in respect...
Brexit: As of exit day (31 January 2020) the UK is no longer an EU Member State. However, in accordance with the Withdrawal Agreement, the UK has entered an...
This Practice Note considers the tax treatment of transactions in intangible assets between related parties within the corporate intangible fixed assets regime (IFA...
The intangible fixed assets regime (IFA regime) has a principal anti-avoidance rule which applies to tax avoidance arrangements. In addition to this principal...
Capital allowances are available for qualifying capital expenditure on know-how where the acquirer is not within the corporate intangibles tax regime in respect of the...
Capital allowances are available and provide a deduction for capital expenditure on acquiring two particular types of intangible fixed asset: • patents, and • know-how...
A company can obtain roll-over relief, under the intangible fixed assets regime (IFA regime) to defer the tax charge on gains on realisation of intangible fixed assets...
The UK has two approaches to taxing IP transactions: • the corporate intangibles tax rules: these apply to IP created or acquired by a company on or after 1 April 2002...
FORTHCOMING CHANGE relating to non-UK resident companies: From 6 April 2020, an extended corporation tax charge will be introduced on non-UK resident companies’ profits...
The realisation of an intangible fixed asset will lead to a tax charge or deduction for the taxpayer company under the intangible fixed assets regime (IFA regime). This...
Part 8 of the Corporation Tax Act 2009 (CTA 2009) is a specific corporation tax regime that applies exclusively to the gains and losses of intangible fixed assets. Note,...
Groups of companies A number of reliefs in respect of intangible fixed assets depend on membership of a group. For example, where there is a disposal of an intellectual...