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The Finance Bill 2020 changes to intangibles

Josh Lom and David Alexander (Herbert Smith Freehills) consider the extent of the reforms to the corporation tax treatment of intangible fixed assets.

Budget 2020 contained an announcement that the taxation of intangible fixed assets held by companies subject to UK corporation tax would be reformed to create a single unified tax regime from 1 July 2020. For some time there have been two separate tax regimes applicable to intangible fixed assets held by these companies:

  • some such assets are taxed under the CGT rules in TCGA 1992 (‘the CGT regime’); and
  • the remainder fall under the regime set out in CTA 2009 Part 8 (‘the intangibles regime’).

One of the most significant features of the intangibles regime compared with the CGT regime is that it often permits tax deductions to be taken in respect...

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