Commentary

D1.629H Corporate intangible regime—assets starting or ceasing to be within the regime

Corporate tax
Corporate tax | Commentary

D1.629H Corporate intangible regime—assets starting or ceasing to be within the regime

Corporate tax | Commentary

D1.629H Corporate intangible regime—assets starting or ceasing to be within the regime

When an intangible asset comes into or exits the corporate intangible regime there is a deemed realisation of the asset as set out below.

Intangible assets coming into the corporate intangible regime

There is a special rule where an asset comes within the corporate regime for intangible assets for the first time in the following circumstances1:

  1.  

    •     where a company becomes UK resident

  2.  

    •     where a non-UK resident company starts to hold the asset for the purposes of:

    1.  

      –     a trade carried on in the UK through a permanent establishment

    2.  

      –     a trade of dealing in or developing UK land

    3.  

      –     carrying on a UK property business on or after 6 April 2020 (see D4.122B), or

    4.  

      –     generating other UK property income within the meaning of CTA 2009, s 5(5) on or after 6 April 2020 (see D4.122B)

  3.  

    •     where the asset ceases to be held for the purposes of a mutual trade or business (see 'Assets excluded except as regards royalties' in D1.603)

The asset is treated as acquired for its accounting value at the time it

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