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HMRC internal manual

Corporate Intangibles Research and Development Manual

Intangible assets excluded from Schedule 29: partial exclusion of asset: apportionment

FA02/SCH29/PARA72 (3) - (5)

Occasionally, an asset may fall partly within and partly outside Schedule 29. Paragraph 72 provides that in those circumstances the rules in Schedule 29 and the other CT rules should apply as if there were two assets, one within Schedule 29 and one outside it. Any apportionment, for example of expenditure on the asset, is to be made on a just andreasonable basis.

This situation could arise for example where an option is granted both for the acquisition or disposal of an intangible fixed asset (and to that extent within Schedule 29 - see CIRD11175) and in respect of other assets (and to that extent within the general rules for derivative contracts in FA02/SCH26 - see CFM11000 onwards andCFM13250 onwards).

Where valuation of intangible assets is an issue see CIRD10240.