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HMRC internal manual

Corporate Intangibles Research and Development Manual

Intangible assets excluded from CTA09/PART8 as special tax rules apply: except as regards royalties: assets held for life assurance business


Life assurance business is subject to special rules for the computation of income, which do not normally use a company’s statutory accounts as their starting point. Goodwill and intangible fixed assets held for life assurance business are therefore excluded from CTA09/PART8 with the exception of royalties. The section makes computer software a further exception to the exclusion. See the Life Assurance Manual (LAM4D.151 to LAM4D.164) for detailed guidance.