Goodwill and customer-related intangibles: UK corporation tax 'relevant assets' rules—6.5% fixed relief, qualifying IP tests, pre-FA 2019 preservation, and realisation debits (CTA 2009 Part 8)
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Practice notes
Corporate intangible assets regime — general rule
Under Part 8 of the Corporation Tax Act 2009, a company’s profits and losses on intangible fixed assets are taken into account for corporation tax as credits and debits in accordance with the accounting treatment of those assets. In essence, GAAP-compliant accounts form the foundation for determining the taxable and relievable amounts connected to a company’s IFAs. This is often summarised as ‘tax follows the accounts’.
There are, however, several exceptions where the corporate intangible assets rules require a departure from the accounting outcome, with IFA credits and debits calculated on a different footing. For broader guidance on the taxation of IFAs, see Practice Note: How intangible fixed assets are taxed—basic principles.
Relevant assets
One instance where the legislation moves away from relying on the company’s accounts concerns ‘relevant assets’. A relevant asset is:
- goodwill in a business or part of a business
- an IFA that consists of information which relates to customers
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Web page updated on 22/05/2026
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