CIRD13530 - Core computational rules: CT computation: intangible assets not used for a trade or property business
FA02/SCH29/PARA34
Intangible assets may be held by a company for purposes outside
those within
CIRD13520 (principally those of a trade
or property business) but which are nevertheless business or
commercial purposes (see
CIRD25070), for example those of an
investment business.
The debits and credits arising from assets used for these
purposes (‘non-trading’ debits and credits) are brought
into the CT computation in a way broadly similar to that adopted
for non- trading items under the loan relationships rules (see
CFM5310).
As a first step it is necessary to aggregate the credits and
debits of this type. Then:
- if the result is a positive sum (i.e. there is an overall gain) it is taxable under Schedule D Case VI,
- if the result is a negative sum (i.e. overall there is a ‘non-trading loss’) it is dealt with in one of the following ways:
- by set off against the company’s total profits for the accounting period ( CIRD13540),
- by surrender as group relief ( CIRD13550),
- in so far as not dealt with by one of the above two methods, it is automatically carried forward to the next accounting period and treated as a non-trading debit of that period.
Change of ownership of company: anti-avoidance rules
Any adjustment to non-trading debits and credits necessary for the reasons mentioned in the last two sub-paragraphs of CIRD13010 should normally be carried out as explained in those sub- paragraphs. There are, however, special rules to identify accounting periods and allocate non- trading debits and credits where there is a change of ownership of a company. See CIRD48050.
