Rollover relief on IFAs

By Tolley
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The following Corporation Tax guidance note by Tolley provides comprehensive and up to date tax information covering:

  • Rollover relief on IFAs
  • Amount available for relief
  • Relief calculation
  • Amortisation adjustment
  • Rollover relief into underlying assets in a company
  • Rollover for pre-April 2002 assets
  • Group rollover

The corporate intangibles tax rules contain a wide rollover relief for dealing with gains on realisations of intangible fixed assets (IFAs). The rules broadly follow the same principles as in the capital gains rollover regime, although there is no interaction between the two forms of rollover relief so the gain on a tangible asset cannot be rolled over into an intangible asset. A company can generally only defer gains on realisations of intangibles only by acquiring other IFAs directly or by utilising the IFA acquisitions of other group companies.

CTA 2009, ss 754–763

Rollover relief cannot be claimed:

  • on deemed realisations of intangible assets (apart from degrouping charges, see the Degrouping charges and elections ― IFAs guidance note
  • where an asset is partly realised and a related party acquires an interest in that asset or some other asset deriving value from the part-realised asset

The new asset must be acquired in the four years beginning 12 months before the date of realisation of the old asset. The claim for rollover relief must specify the asset realised and the expenditure on new assets, as well as the relief claimed. A provisional claim for relief can be made where a company intends to acquire new assets but has not done so by the filing date for the tax return for the period in which the realisation occurred. The provisional claim ceases to have effect four years after the end of the accounting period in which the realisation occurred, unless it is superseded by a claim for relief

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