Commentary

D1.630 Realisations of intangible assets by companies

Corporate tax
Corporate tax | Commentary

D1.630 Realisations of intangible assets by companies

Corporate tax | Commentary

Corporate intangible regime—realisations and relief on reinvestment

D1.630 Realisations of intangible assets by companies

The realisation of an intangible fixed asset and any resulting gain or loss is taxed under the corporate intangible rules rather than being a chargeable gain or loss1. Therefore the gain or loss will either be a trading, property or non-trading debit or credit for tax purposes depending on the nature of the intangible asset realised (see D1.629E).

As with other debits and credits arising from intangible assets, the amounts arising on realisation follows the accounting entries. However, the distinction between the amount of any profit relating to a reversal of previous debits and the amount relating to the proceeds over the cost of the asset is important as rollover relief on reinvestment is only available where sale proceeds exceed original cost (see D1.635–D1.638)2.

Meaning of realisation of intangible assets

A 'realisation of an intangible fixed asset' is defined as any transaction which, in accordance with generally accepted accounting practice (see D1.611), results in3:

  1.  

    •     the asset ceasing to be recognised in the company's balance sheet, or

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