½Û×ÓÊÓƵ

In order for a company to claim rollover relief on the realisation of an intangible asset the asset realised (the old asset) and the asset acquired (the new asset) must satisfy various conditions as set out in D1.635. Where rollover relief is available, both the proceeds of the old asset and the cost recognised for tax purposes of the new, replacement asset are reduced by the 'amount available for relief'¹.

Where qualifying expenditure in relation to the new asset, exceeds the realisation proceeds from the old asset, the amount available for relief is the entire gain on the old asset calculated as the excess of the proceeds over the cost of the old asset². The 'cost of the old asset' is the total of the capitalised expenditure recognised for tax purposes, adjusted accordingly if there is a part realisation or an earlier part realisation³. Further details on part realisations are set out below.

It should be noted that it is the original cost of the asset that is deducted