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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Intangible regime: roll-over relief for companies

Section 84 and Schedules 29 and 30 FA 2002 introduced the Intangible Property reform (IP reform) which has amended the roll-over provisions in respect of companies only by generally removing the availability of relief for intangible fixed assets acquired on or after 1 April 2002. From that date, assets within the Intangibles Regime, for example goodwill and quotas acquired from an unrelated party, are dealt with under the new regime. This provides for companies to obtain tax relief for the cost of these assets based on the amortisation reflected in their accounts.

There are transitional arrangements for disposals and acquisitions in the period around 1 April 2002, see CG61060+.

Note: the availability of roll-over relief on gains arising from the disposal of qualifying assets other than assets within the FA 2002 Intangibles Regime into the acquisition of similar assets is unaffected by the new legislation and continues to be subject to the normal capital gains rules.