Jurisdiction(s):
United Kingdom

Related legal acts

Key definition

Fixed assets definition

What does Fixed assets mean? In legal and transactional practice, fixed assets are the long-term resources of a company—such as land and buildings, plant and machinery, office equipment, vehicles and certain intangibles—held for continuing use in the business to generate profits, rather than for resale. The term is descriptive and used across company law, finance and insolvency. In statutory accounts, the Companies Act 2006 (UK) and Companies Act 2014 (Ireland) balance sheet formats refer to fixed assets, typically analysed as intangible assets, tangible assets and investments. Under UK and Irish GAAP (FRS 102) and IFRS, the parallel concept is non-current assets or property,...

Incorporating overseas branches: UK corporation tax reliefs for chargeable gains and IFAs, EU Mergers Tax Directive treatment, conditions, clawback and practical considerations

Published by a LexisNexis Tax expert

Practice notes

This Practice Note sets out:

the concept of branch incorporation relief available under UK domestic law in relation to:
- corporation tax on chargeable gains — see: Branch incorporation relief for chargeable gains, and
- corporation tax within the intangible fixed assets (IFA) regime in Part 8 of the Corporation Tax Act 2009 — see: Branch incorporation relief for IFAs
the wider UK corporation tax relief on the incorporation of an EU branch following implementation of the Mergers Tax Directive 2009/133/EC, and
some practical points and further tax issues that arise on branch incorporation

Relief cannot be claimed under both the branch incorporation provisions and the rules implementing the Mergers Tax Directive.

Relief on incorporation of overseas branch

Where a UK resident company conducts a trade overseas through a permanent establishment and transfers the whole or part of that trade to a company that is not UK resident, and the transfer triggers a chargeable gain, the UK resident company may claim to defer any corporation tax on that gain, provided specified conditions are satisfied. This is known as ‘branch incorporation relief’...

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Joshua Critchlow

Freshfields

Josh Critchlow is an International Law Clerk at Freshfields based in New York, qualified as a solicitor in England & Wales. Josh is experienced in advising on UK and international tax aspects of a range of cross-border transactions. ...

Web page updated on 21/05/2026

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