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HMRC internal manual

Corporate Intangibles Research and Development Manual

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HM Revenue & Customs
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Intangible assets: FA15 and F2A15 rules for goodwill and relevant assets: FA15 restriction where there are no previous third party acquisition costs

CTA09/PART 8/S849 {#}D

Where there are no previous third party acquisition costs; CTA09/S849D restricts when relief is given for relevant assets by withdrawing debit relief under CTA09/PART 8/Chapter 3.  For example no debit relief is allowed in relation to relevant assets in relation to:

  • Expenditure written off as it is incurred (CTA09/S728)
  • Amortisation or impairment accounting debits (CTA09/S729)
  • Fixed rate debits (CTA09/S731)
  • Reversal of previous accounting gain (CTA09/S732)
  • Royalties in respect of a relevant asset.

A further restriction applies on realisation of the relevant asset, see CIRD44550

For cases where the relevant asset includes previous third party acquisition costs see CIRD44450 onwards.