CIRD11770 - Intangible assets within CTA09/PART8: FA02 rule exceptions: fungible assets: additions to existing holdings outside CTA09/PART8

CTA09/PART8/S900K

CTA09/S900K (previously CTA09/S890 (2) and (3)) provides that a company’s fungible assets of a particular kind and any other kinds of the same fungible assets are to be regarded as different fungible assets.

»Ê¹ÚÌåÓýapp pre-FA02 rule and the special rules in CTA09/CHAPTER16A are therefore applied separately to the different kinds of fungible assets. Thus fungible assets of one kind purchased from a person would be subject to CTA09/PART8 as if they were a different fungible asset from the fungible asset of the same kind already held.

This provision is subject to the anti-avoidance rule described in CIRD11780.

CTA09/S900L (previously CTA09/S891 (2)) provides an identification rule to deal with the situation where, under the provisions described above, a company regarded as holding two or more fungible assets of the same kind sells some of the assets of that kind. »Ê¹ÚÌåÓýapp rule is that the assets sold are regarded as far as possible as reducing the fungible asset that is outside CTA09/PART8 first, restricted assets second, and then standard intangible fixed assets last.