Sarah Gabbai (McDermott Will & Emery) considers two important changes to the IFA regime introduced by the Finance Act 2019.
Prior to the FA 2019 changes to the intangible fixed assets (IFA) rules for goodwill and degrouping charges HMRC and HM Treasury undertook a comprehensive review of both areas during 2018 in addition to the rules for pre-FA 2002 assets. The 7 November consultation response paper contains the conclusions from that review being the key policy drivers for the FA 2019 changes. Broadly these were:
The pre-FA 2019 position on IFA degrouping charges could lead to arbitrary tax outcomes depending on the nature of the assets. Thus some form of alignment with the TCGA 1992 position was justified. However the IFA rules could not simply be a mirror image of TCGA 1992 rules because it would produce inappropriate outcomes where market value rebasing in...
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Sarah Gabbai (McDermott Will & Emery) considers two important changes to the IFA regime introduced by the Finance Act 2019.
Prior to the FA 2019 changes to the intangible fixed assets (IFA) rules for goodwill and degrouping charges HMRC and HM Treasury undertook a comprehensive review of both areas during 2018 in addition to the rules for pre-FA 2002 assets. The 7 November consultation response paper contains the conclusions from that review being the key policy drivers for the FA 2019 changes. Broadly these were:
The pre-FA 2019 position on IFA degrouping charges could lead to arbitrary tax outcomes depending on the nature of the assets. Thus some form of alignment with the TCGA 1992 position was justified. However the IFA rules could not simply be a mirror image of TCGA 1992 rules because it would produce inappropriate outcomes where market value rebasing in...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
