½Û×ÓÊÓƵ

Rollover relief on IFAs

Produced by a Tolley Corporation Tax expert
Corporation Tax
Guidance

Rollover relief on IFAs

Produced by a Tolley Corporation Tax expert
Corporation Tax
Guidance
imgtext

The corporate intangibles tax rules contain a wide rollover relief for dealing with gains on realisations of intangible fixed assets (IFAs). The rules broadly follow the same principles as in the capital gains rollover regime, although there is no interaction between the two forms of rollover relief so the gain on a tangible asset cannot be rolled over into an intangible asset. (Although a capital gain on a pre-April 2002 intangible asset can be rolled into in IFA asset ― see below.) A company can generally only defer gains on realisations of intangibles by acquiring other IFAs directly or by utilising the IFA acquisitions of other group companies.

Rollover relief cannot be claimed:

  1. •

    on deemed realisations of intangible assets (apart from degrouping charges, see the Degrouping charges and elections ― IFAs guidance note

  2. •

    where an asset is partly realised and a related party acquires an interest in that asset or some other asset deriving value from the part-realised asset

The new asset must be acquired in the four years beginning 12 months before

Continue reading the full document
To gain access to additional expert tax guidance, workflow tools, and tax research, register for a free trial of Tolley+â„¢
Powered by

Popular Articles

SEIS and EIS ― overview

SEIS and EIS ― overviewThe seed enterprise investment scheme (SEIS) and enterprise investment scheme (EIS) are very similar schemes which offer substantial tax incentives to investors in companies which qualify. The tax incentives for SEIS and EIS investments are intended to encourage investment in

14 Jul 2020 13:31 | Produced by Tolley Read more Read more

Allowable deductions for employee-related expenses

Allowable deductions for employee-related expensesThis guidance note covers the tax treatment of some common types of trading expenditure relating to employees. Some of these are disallowable under general principles, for example the wholly and exclusively test or capital versus revenue expenditure.

14 Sep 2022 09:49 | Produced by Tolley Read more Read more

Corporate interest restriction ― administrative aspects

Corporate interest restriction ― administrative aspectsThe corporate interest restriction (CIR) regime has some specific administrative rules in addition to the general administrative requirements for corporation tax returns. This guidance note does not include commentary on provisions that are

14 Jul 2020 11:19 | Produced by Tolley Read more Read more