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Home / Simons-Taxes /Corporate tax /Part D1 Corporation tax generally /Division D1.6 Intangible fixed assets /Corporate intangible regime—accounting, market value and tax adjustments / D1.614 Corporate intangible regime—tax adjustments
Commentary

D1.614 Corporate intangible regime—tax adjustments

Corporate tax

The starting point in determining the debits or credits recognised under the corporate intangible regime are the debits and credits in relation to a intangible fixed asset that are recognised in a company's accounts (see D1.611). These are then subject to any adjustment required by the corporate intangible regime, or the transfer pricing provisions. For details of the accounting credits and debits which are to be adjusted see D1.620–D1.625 and D1.626–D1.629C respectively but essentially they would include amounts taken to profit and loss and also the cost of the intangible asset where the asset is capitalised and then written down for accounting purposes or written down under a fixed rate election (see D1.628).

Having established the accounting debits and credits, the specific adjustments under the corporate intangible regime are set out in detail below but there may also be adjustments required for items which are:

  1. Ìý

    •ÌýÌýÌýÌý royalty payments between related parties, see 'Royalties payments to a related party' in D1.601B

  2. Ìý

    •ÌýÌýÌýÌý intangible assets with nil accounting values, see 'Assets with nil accounting values' in D1.611A

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