Overview of corporate intangibles tax regime

By Tolley

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

  • Overview of corporate intangibles tax regime
  • Summary of corporate intangible regime
  • Date of acquisition or creation

This document covers these in detail, along with differences in tax treatment pre-and post-1 April 2012; tax adjustments; change in accounting policy; IAS 38 adoption, negative goodwill; and election for writing down at fixed rate.


For companies, the taxation of intangible fixed assets acquired or created after 1 April 2002 is governed by CTA 2009, ss 711–906 (Part 8). The corporate tax treatment essentially follows the treatment of intangibles in the accounts. There are however restrictions on the deductibility of debits in relation to goodwill and other customer-related intangible assets depending on the date of acquisition or creation, see the Goodwill and other customer-related intangible assets guidance note.

Prior to Finance Act 2002, there was no harmonised regime dealing with the taxation of corporate intangibles ― this continues to be the case for ‘old’ corporate intangibles.

Summary of corporate intangible regime

Most intangible assets are within the corporate intangible regime but there are some types of expenditure which are excluded completely or excluded apart from royalties derived from the intangible asset. The corporate intangible regime also interacts with other corporate tax regimes where the same expenditure qualifies for both regimes. More details on these topics are set out in the Definition of intangibles guidance note.

Debits and credits on intangible assets are generally treated for tax in the same way as they are included in the accounts but there are tax adjustments which follow similar rules

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