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HMRC internal manual

Corporate Intangibles Research and Development Manual

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Core computational rules: CT computation: intangible assets not used for a trade or property business

CTA09/PART8/S751

Intangible assets may be held by a company for purposes outside those within CIRD13520 (principally those of a trade or property business) but which are nevertheless business or commercial purposes (see CIRD25070), for example those of an investment business.

The debits and credits arising from assets used for these purposes (‘non-trading’ debits and credits) are brought into the CT computation in a way broadly similar to that adopted for non-trading items under the loan relationships rules (see CFM32010).

As a first step it is necessary to aggregate the credits and debits of this type. Then:

  • if the result is a positive sum (i.e. there is an overall gain) it is taxable as miscellaneous income,
  • if the result is a negative sum (i.e. overall there is a ‘non-trading loss’) it is dealt with in one of the following ways:

    • by set off against the company’s total profits for the accounting period (CIRD13540),
    • by surrender as group relief (CIRD13550),
    • in so far as not dealt with by one of the above two methods, it is automatically carried forward to the next accounting period and treated as a non-trading debit of that period.

    Change of ownership of company: anti-avoidance rules

    Any adjustment to non-trading debits and credits necessary for the reasons mentioned in the last two sub-paragraphs of CIRD13010 should normally be carried out as explained in those sub-paragraphs. There are, however, special rules to identify accounting periods and allocate non-trading debits and credits where there is a change of ownership of a company. See CIRD48050.