Corporation Tax

Group intangible fixed assets

Produced by Tolley
  • 16 Dec 2021 16:31

The following Corporation Tax guidance note Produced by Tolley provides comprehensive and up to date tax information covering:

  • Group intangible fixed assets
  • Groups
  • Definition
  • Intangibles ― intra-group transfers

Group intangible fixed assets


There is specific legislation which deals with groups of companies and intangible fixed assets. This looks at:

  1. definition of ‘group’

  2. intra-group transfers

  3. rollover relief between group companies

  4. rollover relief on acquisition of a subsidiary

  5. degrouping charges, including reallocation of the charge, allocation of rollover relief, and recovery from another group company or director

  6. intra-group payments for reliefs

CTA 2009, ss 764–799

This guidance note covers the definition of ‘group’ and intra-group transfers. For further guidance on the other areas, see the following guidance notes:

  1. Degrouping charges and elections ― IFAs

  2. Rollover relief on IFAs

  3. Reorganisations / reconstructions ― IFAs


The definition of a group follows the definition for capital gains purposes. A group is defined as:

  1. a parent company and its 75% subsidiaries

  2. 75%

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