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HMRC internal manual

Corporate Intangibles Research and Development Manual

Intangible assets: FA15 and F2A15 rules for goodwill and relevant assets: introduction

FA15/S26 {#} & F2A15/S33


Two new rules were introduced into CTA09/PART 8 by FA15/S26 and F2A15/S33.  Both of these rules restrict when and how relief is given under CTA09/PART 8 in respect of goodwill and other relevant assets.  These rules apply

  • In relation to goodwill and certain customer related intangible assets when a company acquires relevant assets from a related party individual, or a firm, where one of the members is related to the company (normally referred to as an ‘incorporation’).  This rule is effective for incorporations occurring on or after 3 December 2014.
  • This rule is extended to include all other goodwill and certain customer related intangible asset acquisitions for all acquisitions occurring on or after 8 July 2015.

Acquisitions of relevant intangible assets that occur before these dates are not affected by the new rules introduced by FA15 and F2A15.

The guidance on the goodwill restriction is in two parts:

  • For guidance on the changes that were introduced by F2A15/S33 from 8 July 2015 see CIRD44100 onwards.
  • For guidance on the FA15 changes in respect of related party incorporations occurring between 3 December 2014 and 8 July 2015 see CIRD44300 onwards.