Non-trading debits and credits in respect of intangible fixed assets are brought into account as a net aggregate amount (see D1.629E). This does not fit easily with the UK's double taxation relief system, where essentially each source is viewed on a stand alone basis in calculating the double taxation relief position (see E6.431)1. The corporate intangible regime therefore has special rules for dealing with double taxation relief on non-trading items2.
In computing double taxation relief, the corporate intangible regime allows a source of non-trading income, which has suffered foreign tax, to be viewed on a stand alone basis without deducting any non-trading debits3. Non-trading debits on intangible fixed assets must still be allocated across sources of income, but they can be allocated against sources
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