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HMRC internal manual

Corporate Intangibles Research and Development Manual

Reinvestment relief: general matters and conditions to be satisfied: by new asset: deemed acquisition: reacquisition of the same asset

CTA09/S762 AND S763(2)

Deemed acquisition

In some circumstances, CTA09/PART8 deems an asset to be realised and reacquired, for example at market value in the context of a ‘degrouping’ (CIRD20460) or at its accounting value when the company becomes resident in the UK (CIRD47020). Expenditure deemed to have been incurred in these circumstances can never be taken into account for reinvestment relief.

Occasions where there is a deemed reacquisition of an asset need to be distinguished from those where there is a real acquisition but, under CTA09/PART8, the acquisition is regarded as taking place for an amount which is different from the actual amount paid.

Actual reacquisition of same asset

CTA09/S762 enables relief to be given where a company realises an asset but subsequently reacquires it, for example as a result of a change of business plans.