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. (Although a capital gain on a pre-April 2002 intangible asset can be rolled into an IFA asset ― see below.) A company can generally only defer gains on realisations of intangibles by acquiring other IFAs directly or by utilising the IFA acquisitions of other group companies.

Rollover relief cannot be claimed:

1. •

   on deemed realisations of intangible assets (apart from degrouping charges, see the Degrouping charges and elections ― IFAs guidance note

2. •

   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