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HMRC internal manual

Corporate Intangibles Research and Development Manual

Intangible assets excluded from CTA09/PART8 as special tax rules apply: introduction

CTA09/PART8/S810-S816A

The exclusions in these sections reflect the existence of special tax rules for certain types of intangible asset and for goodwill and intangible assets held for certain purposes. Without these exclusions the provisions in CTA09/PART8 would override these special tax rules. (See CIRD10110 for the relationship generally between the provisions of CTA09/PART8 and other CT rules).

The specific background is mentioned in the paragraph dealing with each exclusion.

Unlike the exclusions described in CIRD25025 onwards the provisions in S810-S816A do not exclude all matters in respect of those assets from the provisions of CTA09/PART8. These provisions provide for two types of exclusion:

  • the exclusion of assets from CTA09/PART8 except as regards royalties (see CIRD25110 onwards),
  • research and development and other computer software (see CIRD25150 onwards).

 

However CTA09/S804 relates to websites on which capital allowances have been claimed, entirely excluding the asset from CTA09/PART8 - see CIRD25145.