This provision is unlikely to be in point in the case of
companies resident in the UK since all their activities will
normally fall within the charge to CT. But a company that is not
resident in the UK will only be within the charge to CT in
connection with a trade carried on through a permanent
establishment in the UK. To the extent intangible assets are used
for the purposes of activities carried on through other parts of
the company they will be excluded by this provision.
Where an intangible asset is partly used for the purpose of
the activities of a permanent establishment in the UK of a
non-resident company and partly for other purposes the
apportionment rules in FA02/SCH29/PARA72 will be in point - see
CIRD25015.
This provision may be relevant to goodwill, as well as to
more narrowly defined intangible fixed assets. - see
CIRD11170.
