»Ê¹ÚÌåÓýapp

»Ê¹ÚÌåÓýapp intangible asset regime incorporates various rules that modify the regime for groups of companies. »Ê¹ÚÌåÓýappse are dealt with at CIRD40000 onwards. »Ê¹ÚÌåÓýappy are similar in concept to, and are broadly modelled on, the CG regime for groups.

Definition of group

A group member, for intangible asset purposes, has to be both part of a sequence of at least 75% subsidiaries of the principal company, and, in terms of effective control, must be at least a 51% subsidiary of the principal company of the group. An example of how this test works is at CIRD40035.

Intra group transfers are usually tax-neutral

»Ê¹ÚÌåÓýapp most important rule affecting groups is that transfers of intangible assets between group members are usually on a ‘tax-neutral basisâ€�. So if group member A acquires an intangible asset from group member B, there is no immediate gain or loss calculation for tax purposes, and instead group member A ‘inheritsâ€� the tax position of group member B with regard to the asset. A will be treated as having acquired the asset for the same cost as B did, and as having amortised it to the same extent. »Ê¹ÚÌåÓýapp tax neutral rule does not apply to transfers involving group members outside the corporation tax net.

Degrouping rules

Because transfers within a group may have taken place on a tax neutral basis there are various rules designed to trigger an intangible asset degrouping adjustment when a company which has been a recipient of a group transfer leaves the group. »Ê¹ÚÌåÓýappse arrangements are similar to the provisions for triggering a CG computation. »Ê¹ÚÌåÓýappy are dealt with at CIRD40500 onwards.

Reinvestment relief

As mentioned above at CIRD10170, the rules for reinvestment relief are modified where groups of companies are involved.