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HMRC internal manual

Business Income Manual

Capital/revenue divide: intangible assets: contents

In his classic definition, Lord Cave referred to an asset or advantage of an enduring benefit (see BIM35010). Businesses spend money on acquiring tangible assets like machines and business premises. But they may also acquire intangible assets or advantages of other kinds. These latter may take the form of various kinds of intellectual property, or leases and other interests over land. Or they may be less well defined, like the disappearance of a competitor from the market. Where the intangible asset or advantage has sufficient quality of endurance the expenditure involved will be capital.

The guidance that follows describes a number of cases involving intangible assets that have come before the courts.

  1. BIM35501
    Corporation Tax intangible assets regime
  2. BIM35505
    General introduction
  3. BIM35510
    Acquisition of commercial advantages
  4. BIM35515
    Acquisition of business franchises or licences
  5. BIM35525
    Fees in connection with the capital structure of a business
  6. BIM35530
    Profit making structure
  7. BIM35535
    Profit making structure - more recent developments
  8. BIM35540
    Payment to preserve existing business or asset structure
  9. BIM35545
    Payment to change existing business or asset structure
  10. BIM35550
    Exclusivity ties
  11. BIM35555
    Exclusivity ties - reimbursed repairs, etc
  12. BIM35560
    Exclusivity ties - acquiring an interest in land
  13. BIM35565
    Changes to company charter
  14. BIM35570
    Cost of an anti-nationalisation campaign
  15. BIM35575
    Expenditure in connection with loans and other liabilities
  16. BIM35580
    Incidental expenditure incurred in financing the business
  17. BIM35585
    Release from an onerous agreement
  18. BIM35590
    Getting rid of an unsatisfactory employee
  19. BIM35595
    Payment to bind employee with a restrictive covenant
  20. BIM35600
    Compensation for sterilising an asset
  21. BIM35605
    Purchase of tipping sites by a waste disposal company
  22. BIM35615
    Costs of incorporating a new company
  23. BIM35620
    Making good dilapidations as a condition of the lease
  24. BIM35625
    Surrender of onerous lease
  25. BIM35630
    Assignment of onerous lease
  26. BIM35635
    Payment to another company to cease production for a period
  27. BIM35640
    Expenditure developing a brand name
  28. BIM35645
    Building society demutualisation
  29. BIM35650
    Money injected into a subsidiary as a condition of sale
  30. BIM35655
    Liabilities assumed as part of the consideration for purchase of a business
  31. BIM35660
    Proprietor's training courses