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HMRC internal manual

Corporate Intangibles Research and Development Manual

Intangible assets excluded from CTA09/PART8 as special tax rules apply: research and development and other computer software: overview

CTA09/PART8/S814 and S815

These exclusions cover:

  • intangible fixed assets representing expenditure by a company on research and development (see CIRD25160),
  • intangible fixed assets representing capital expenditure by a company on computer software in respect of which an election has been made (see CIRD25180).


In broad terms the purpose of these provisions is to ensure that:

  • relief for expenditure of this kind continues to be available outside CTA09/PART8; but
  • receipts from the exploitation of those assets are brought to account as income, whether under CTA09/PART8 or otherwise.