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HMRC internal manual

Corporate Intangibles Research and Development Manual

Intangible assets excluded from CTA09/PART8: partial exclusion of asset: apportionment


Occasionally, an asset may fall partly within and partly outside CTA09/PART8. S802 provides that in those circumstances the rules in CTA09/PART8 and the other CT rules should apply as if there were two assets, one within CTA09/PART8 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 CTA09/PART8 - see CIRD11175) and in respect of other assets (and to that extent within the general rules for derivative contracts in CTA09/PART7/CHAPTER4 - see CFM11000 onwards and CFM13250 onwards).

Where valuation of intangible assets is an issue see CIRD10240.