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HMRC internal manual

Corporate Intangibles Research and Development Manual

Intangible assets: Restrictions for goodwill and relevant assets: No business or no qualifying IP acquired



CTA09/S879I restricts debit relief in relation to acquisitions of relevant assets that are either

  • not acquired as part of business acquisition (CTA09/S879I(1), or
  • acquired as part of a business acquisition but that acquisition does not include any qualifying IP.  

CT09/S879I broadly replicates the restriction that previously existed in CTA09/S816A.


Note that, in order to be taken into account, qualifying IP must be acquired for use on a continuing basis in the course of the business (so that it is an “intangible fixed asset” in relation to the acquiring company).  If, therefore, a company doesn’t intend to use it, that IP cannot be qualifying IP.  See CIRD11170 for the definition of intangible fixed asset.