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HMRC internal manual

Corporate Intangibles Research and Development Manual

Intangible assets: avoidance: contents

  1. CIRD48010
  2. CIRD48020
    Structural defences and their limitations
  3. CIRD48030
    Specific rules
  4. CIRD48040
    More general CT rules
  5. CIRD48050
    Change of ownership of company
  6. CIRD48105
    Tax-driven transactions: approach to take
  7. CIRD48110
    Tax-driven transactions: outline of provision
  8. CIRD48120
    Tax-driven transactions: relationship of anti-avoidance rule with other provisions
  9. CIRD48130
    Tax-driven transactions: whether tax avoidance main object
  10. CIRD48140
    Tax-driven transactions: circumstances where anti-avoidance rule may be in point
  11. CIRD48150
    Tax-driven transactions: nature of counteraction
  12. CIRD48200
    Measures in FA03/S184: background
  13. CIRD48230
    Measures in FA03/S184: how they work
  14. CIRD48250
    Measures in FA03/S184: position for accounting periods ending at different times
  15. CIRD48260
    Measures in F2A05/S41: change to rules: market value rules
  16. CIRD48270
    Measures in F2A05/S41: change to rules: related parties rules
  17. CIRD48280
    New measures in FA06/S77: change to rules: new assets derived from companies’ existing assets
  18. CIRD48290
    New measures in FA09/S70: confirmation of rules: time of creation of goodwill and certain other internally generated assets
  19. CIRD48300
    New measures in FA11/S62: confirmation of rules: goodwill and intangible assets relating to an oil & gas licence excluded
  20. CIRD48320
    Intangible assets exchanged for other assets recognised at net book value (step-up schemes)
  21. CIRD48330
    Accounting step-up schemes involving transfers
  22. CIRD48340
    Intangible asset realisation involving non-monetary receipts
  23. CIRD48350
    Related party licence not granted at market value
  24. CIRD48360
    Related party licence examples