Commentary

D1.647 Intangible assets—rollover relief and groups

Corporate tax
Corporate tax | Commentary

D1.647 Intangible assets—rollover relief and groups

Corporate tax | Commentary

D1.647 Intangible assets—rollover relief and groups

Rollover relief on intangibles is extended to groups where another group company acquires qualifying intangible assets and also where the group invests in a company which owns qualifying intangible assets, both circumstances are detailed below.

Intangible assets—rollover relief within a group of companies

Rollover relief on reinvestment is extended to expenditure incurred by one company where an asset has been realised by another company which is a member of the same group1. Provided that certain conditions are satisfied, the two companies are treated as the same company for rollover relief purposes. The conditions are that2:

  1.  

    •     the realising company must be a member of the group at the time it realises the old asset

  2.  

    •     the replacement expenditure must be made by a company that is a member of the group at the time it incurs expenditure; however, the two companies do not have to be members of the group at the same time

  3.  

    •     the company incurring the expenditure is not a 'dual-resident investing company' (see D4.133)

  4.  

    •     the new asset must be a 'chargeable intangible

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