Intangible fixed assets

Intangible fixed assets regime (IFA regime)

The IFA regime, contained in Part 8 of the Corporation Tax Act 2009, was introduced in 2002 for the purposes of taxing companies in respect of their intangible fixed assets, which are broadly intellectual property (IP) and goodwill.

For more details, see Practice Notes: What is an intangible fixed asset? and Excluded intangible fixed assets.

The IFA regime aims to tax and relieve profits and losses in respect of intangible assets as income, generally in accordance with accounting principles.

The IFA regime provides more opportunities for corporation tax relief than was previously the case. For more details, see Practice Note: How intangible fixed assets are taxed—basic principles and Intangible fixed assets—anti-avoidance.

Tax treatment of intangible assets outside the IFA regime

Before the introduction of the IFA regime, companies were subject to corporation tax in respect of intangible assets on the basis of general tax principles (largely enshrined in case law) that still apply for individuals. Broadly, outside of the IFA regime, acquisitions and disposals of IP (other than patents) held otherwise than as trading stock are