Commentary

D1.635 Intangible rollover relief—summary and qualifying conditions

Corporate tax
Corporate tax | Commentary

D1.635 Intangible rollover relief—summary and qualifying conditions

Corporate tax | Commentary

D1.635 Intangible rollover relief—summary and qualifying conditions

The corporate intangible regime provides a self-contained 'rollover relief' enabling gains on realisation of an intangible fixed asset (the 'old asset') to be rolled over against reinvestment into other intangible fixed assets (the 'new assets')1. Rollover relief for intangible assets is restricted to gains on realisation (see D1.630) as opposed to other taxable credits (see D1.621–D1.625).

The corporate intangible regime provisions for rollover mirror closely capital gains rollover relief (see Division C3.3) and there are similar provisions in the corporate intangible regime which extend rollover within groups of companies, see D1.647.

In contrast to the capital gains rollover relief provisions, gains realised on intangible assets are eligible for rollover relief, both where they are used by a company for a trade or held by the company for investment purposes. In certain circumstances gains on intangible assets can be rolled over against reinvestment in a company which owns intangible assets, as if those assets had been acquired directly, see D1.647.

To qualify for rollover relief certain conditions must be met regarding the old and new assets, see below. Details of how the relief is given is

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