Intangible fixed asset meaning

Ripe Ltd v HMRC [2025] UKFTT 1606 (TC) Mr and Mrs Glazer had been partners at an accountancy practice (GCA). They left GCA in May 2007 intending to establish a new firm with a third individual, Mr Dewani. To operate the new venture, the Glazers set up a limited liability partnership (LLP). Later in 2007, Mr Glazer acquired from GCA a licence to a client list and associated data (the asset). Instead of placing the asset within the LLP, the Glazers incorporated the taxpayer company; Mr Glazer then sold the asset to that company, which subsequently licensed it to the LLP. This structure was said to be required to ring-fence the respective client portfolios of the Glazers and Mr Dewani in case the merger failed. No formal licence agreement existed between the LLP and the company. The company received a licence fee and, later on, a share of the LLP’s profits. It recorded the asset as goodwill, amortised straight-line over ten years, and claimed corporation tax deductions for the...

In this issue Companies and corporation tax International Taxes management and litigation VAT Devolved taxes Budgets and Finance Bills Daily and weekly news alerts New and updated content Dates for your diary Trackers Useful information Companies and corporation tax FTT rules that a licence for a client list and associated data constituted an intangible fixed asset for corporation tax (Ripe Ltd v HMRC). As noted in last week’s highlights, in Ripe Ltd v HMRC [2025] UKFTT 1606 (TC), the First-tier Tax Tribunal (FTT) upheld the taxpayer’s appeal against closure notices and assessments that had refused corporation tax relief for amortisation of a licence over a client list and related data, HMRC’s stance being that the licence was not an intangible fixed asset (IFA). Although the issues arose before the successive regimes governing goodwill and customer-related IFAs (labelled ‘relevant assets’) from 3 December 2014, the judgment usefully reiterates core principles on the taxation of IFAs....

Chemidex Generics Ltd v HMRC [2024] UKFTT 1146 (TC). Chemidex Generics Ltd (CGL) obtained IP tied to certain out-of-patent pharmaceutical products, together with related assets such as marketing authorisations (the Product Assets), from a partnership created by Mr Navin Engineer and Mrs Varsha Engineer (together, the Partners). In most cases, the Partners had put in place profit sharing agreements (PSAs) with Chemidex Pharma Ltd (CPL), a company wholly owned by them, as was CGL. Under those PSAs, CPL held the right to exploit the Product Assets. Following the transfer, CGL owned the Product Assets and enjoyed the benefit of the various PSAs. It was common ground that the Product Assets were chargeable intangible fixed assets (IFAs) and therefore came within the IFA code in Part 8 of the Corporation Tax Act 2009 (CTA 2009). It was also common ground that CGL and the Partners were ‘related parties’ (within the meaning of CTA 2009, s 835). Therefore, in accordance with CTA 2009, s 845,...

Before disposing of a business or trade When planning a disposal, a corporate seller must choose the most suitable deal structure. Commercial drivers should lead, yet securing a tax-efficient outcome will inevitably be a key concern. The initial choice is whether to transfer: the business and its underlying assets (a business sale), or the shares in a subsidiary that holds the business and assets (a share sale) Broadly, sellers tend to prefer a share sale: it offers a straightforward exit and, where the substantial shareholdings exemption (SSE) applies, any gain is exempt from tax. An asset deal is more likely to crystallise tax charges and leaves any pre-completion tax liabilities with the seller. This Practice Note does not address individual sellers or business asset disposal relief (BADR). For more on BADR, see Practice Note: CGT—business asset disposal relief (formerly entrepreneurs' relief)...

FORTHCOMING CHANGE relating to the modernisation of stamp taxes on shares framework: In 2027, stamp duty and SDRT are set to give way to a unified, self-assessed levy on securities—the securities transfer charge (STC)—to be paid and reported through a new digital portal. In broad terms, the STC’s design will align with the proposals for that tax set out in the 2023 consultation. Finance Bill 2026 (FB 2026) creates a power, commencing on Royal Assent, for secondary legislation that will enable taxpayers to pilot the digital service by self-assessing their stamp taxes on securities obligations and submitting transactions electronically via the service. This will allow reporting and payment to be handled online as part of the modernisation of stamp taxes on shares. For detailed coverage of the modernisation of stamp taxes on securities, see: News Analyses: Budget 2025—Tax analysis—Stamp and transfer taxes Tax update spring 2025—Stamp taxes on shares modernisation Tax update spring 2025—Tax analysis—Stamp and transfer taxes TAMD 2023—Stamp taxes on...

Where a company disposes of an intangible fixed asset (IFA) that falls within the corporate intangible assets regime in Part 8 of the Corporation Tax Act 2009 (CTA 2009), any gain or loss arising is recognised for corporation tax as, as appropriate, a credit or a debit. Amounts brought in under CTA 2009, Pt 8 are dealt with as income items, both for charge and relief. Consequently, the usual income/capital divide under general tax law is disapplied. Instead, a credit or debit on the realisation of an IFA is treated either (i) as a receipt or expense of a trade or of a property business, or (ii) where the IFA is not held for the purposes of a trade or property business, as a non-trading credit or a non-trading debit. For further detail on the taxation of IFAs, refer to Practice Note: How intangible fixed assets are taxed—basic principles...

[ Letterhead ] [ Addressed to HMRC Officer ] [ Date ] We jointly make an election under section 792 of the Corporation Tax Act 2009 (CTA 2009) that [ the whole OR [ insert a specific amount, a percentage or a fraction ] ] of the chargeable realisation gain arising on the deemed realisation and reacquisition of the intangible assets is to be regarded as attributable to [ full company name ] (Company B) rather than [ full company name ] (Company A)...

This Precedent Serves to log the assets held by an organisation, for example land, buildings, office machinery, manufacturing machinery, software, data, people, intellectual property items. Please click to access an Excel edition of this register. Please note the register is produced in Excel and therefore currently cannot be downloaded directly into Word...