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Home / Simons-Taxes /Corporate tax /Part D1 Corporation tax generally /Division D1.6 Intangible fixed assets /Corporate intangible regime—tax computational rules / D1.629H Corporate intangible regime—assets starting or ceasing to be within the regime
Commentary

D1.629H Corporate intangible regime—assets starting or ceasing to be within the regime


Corporate tax

When an intangible asset comes into or exits the corporate intangible regime there is a deemed realisation of the asset as set out below.

Intangible assets coming into the corporate intangible regime

There is a special rule where an asset comes within the corporate regime for intangible assets for the first time in the following circumstances1:

  1. Ìý

    •ÌýÌýÌýÌý where a company becomes UK resident

  2. Ìý

    •ÌýÌýÌýÌý where a non-UK resident company starts to hold the asset for the purposes of:

    1. Ìý

      –ÌýÌýÌýÌý a trade carried on in the UK through a permanent establishment

    2. Ìý

      –ÌýÌýÌýÌý a trade of dealing in or developing UK land

    3. Ìý

      –ÌýÌýÌýÌý carrying on a UK property business on or after 6 April 2020 (see D4.122B), or

    4. Ìý

      –ÌýÌýÌýÌý generating other UK property income within the meaning of CTA 2009, s 5(5) on or after 6 April 2020 (see D4.122B)

  4. Ìý

    •ÌýÌýÌýÌý where the asset ceases to be held for the purposes of a mutual trade or business

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