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CTA09/PART8/S751

Intangible assets may be held by a company for purposes outside those within CIRD13520 (principally those of a trade or property business) but which are nevertheless business or commercial purposes (see CIRD25070), for example those of an investment business.

»Ê¹ÚÌåÓýapp debits and credits arising from assets used for these purposes (‘non-tradingâ€� debits and credits) are brought into the CT computation in a way broadly similar to that adopted for non-trading items under the loan relationships rules (see CFM32010).

As a first step it is necessary to aggregate the credits and debits of this type. »Ê¹ÚÌåÓýappn:

• if the result is a positive sum (i.e. there is an overall gain) it is taxable as miscellaneous income,
• if the result is a negative sum (i.e. overall there is a ‘non-trading lossâ€�) it is dealt with in one of the following ways:

• by set off against the company’s total profits for the accounting period (CIRD13540),
• by surrender as group relief (CIRD13550),
• in so far as not dealt with by one of the above two methods, it is automatically carried forward to the next accounting period.

Change of ownership of company: anti-avoidance rules

Any adjustment to non-trading debits and credits necessary for the reasons mentioned in the last two sub-paragraphs of CIRD13010 should normally be carried out as explained in those sub-paragraphs. »Ê¹ÚÌåÓýappre are, however, special rules to identify accounting periods and allocate non-trading debits and credits where there is a change of ownership of a company. See CIRD48050.