Temple Tax Chambers

This Practice Note explains that a transfer of an intangible fixed asset from one group company to another is treated as tax-neutral. There is no realisation of the intangible fixed asset by the transferor and the transferee ‘steps into the shoes’ of the transferor with regard to original expenditure on and subsequent amortisation of the asset. A degrouping charge may arise where the transferee company ceases to be a member of the group within six years. Produced in partnership with Anne Fairpo, barrister.

ARCHIVED: This Practice Note has been archived and is not maintained. This Practice Note explains that large companies are entitled to corporation tax relief for expenditure incurred before 1 April 2017 on research and development (R&D) relating to certain vaccines and medicines and sets out what types of expenditure on qualifying R&D qualifies for such relief. It also explains how the additional deduction may be claimed. The relief does not apply to expenditure incurred on or after 1 April 2017. This Practice Note was produced in partnership with Anne Fairpo, barrister.

This Practice Note examines the purpose of intellectual property (IP) valuation and introduces two methods of valuation (cost-based method and economic-based method). It then explains why and how IP is valued. In general, the principal aim of the valuation exercise will be to establish the market value of the IP. This note explains the different approaches used, being a comparison approach, an income approach and a cost approach. Each broad approach encompasses various valuation methods.

This Practice Note considers the tax treatment where a company’s intangible fixed assets are realised. A company’s receipts from exploiting assets falling within the intangible fixed assets regime are charged to corporation tax as income. A corporation tax charge may also arise on a realisation or part-realisation of an intangible asset. Produced in partnership with Anne Fairpo, barrister.

This Practice Note considers the meaning of an intangible fixed asset for corporation tax purposes. An intangible fixed asset has the same meaning for tax purposes as for accounting purposes and specifically includes internally generated assets. The definition covers goodwill and specific items of intellectual property, including patents, trade marks, registered designs, copyrights and design rights. This Practice Note was produced in partnership with Anne Fairpo, barrister.

This Practice Note looks at the definition of a group of companies for the purposes of the intangible fixed assets regime, which in practice follows the definition for capital gains tax purposes. A number of reliefs in respect of intangible fixed assets depend on membership of a group. This Practice Note was produced in partnership with Anne Fairpo, barrister.

This Practice Note outlines the UK rules on withholding tax on royalties or other payments in respect of intellectual property (IP), including the changes introduced by the Finance Act 2016. This Practice Note was produced in partnership with Anne Fairpo, barrister.