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HMRC internal manual

Corporate Intangibles Research and Development Manual

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HM Revenue & Customs
Updated
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Intangible assets: international issues: introduction

Where provisions described

This section of the manual describes certain provisions relevant to the treatment of goodwill and intangible assets under the rules in FA02/SCH29 that have a particular international dimension. Other provisions with an international dimension described elsewhere are listed below.

Provisions described in this section

  • asset moving into or out of UK tax net without changing ownership - CIRD47020 and CIRD47030,
  • company becomes resident in the UK - CIRD47020,
  • asset held by a non-resident company begins to be used in its UK trade carried on through a permanent establishment in the UK - CIRD47020,
  • company ceasing to be resident in the UK - CIRD47030,
  • asset held by a non-resident company ceasing to be used in its UK trade carried on through a permanent establishment in the UK - CIRD47030,
  • deferral of taxable credit arising where company ceases to be resident in the UK - CIRD47040,
  • application of transfer pricing rules to goodwill and intangible assets within Schedule 29 - CIRD47060.

Provisions described elsewhere

  • transfer of overseas trade carried on through a permanent establishment to non- resident - CIRD42040 and CIRD42060,
  • transfer of UK trade involving companies resident in different member States - CIRD42030,
  • avoidance using cross-border structures - CIRD48140.