½Û×ÓÊÓƵ

The corporate intangible regime applies to all intangible fixed assets, as set out in D1.602 however certain assets are expressly excluded¹. Where an asset is excluded, an option or other right to acquire or dispose of such an asset is also excluded².

There are three kinds of exclusion³:

1. Ìý

   •ÌýÌýÌýÌý assets entirely excluded

2. Ìý

   •ÌýÌýÌýÌý assets excluded except as regards royalties

3. Ìý

   •ÌýÌýÌýÌý assets excluded to a specified extent

When an asset is partially excluded, separate assets are deemed to exist within and outside the regime and any other corporation tax rules apply to the part deemed to be a separate asset outside the corporate intangible regime⁴. Any apportionment needed is made on a just and reasonable basis⁵.

For assets excluded except as regards royalties, the effect is to allow a company to bring royalties into account for tax purposes on the same basis as they are recognised in the company's accounts. This allows the simpler treatment of royalties afforded by the corporate intangible