The debits and credits due under FA02/SCH29 are calculated in
accordance with the fractions set out in Part 1 of the Schedule. In
general these are the accounting adjustment multiplied by the
fraction tax value/accounting value. The tax value may be different
from the accounting value where, for example, disallowable items
(such as entertaining) are reflected in the accounting charge. The
tax written down value is in general the cost of the asset less any
tax debits (or plus any credits) given since the start of the
intangibles regime.
The effect of FA02/SCH29/PARA129 (3) is that the tax written
down value is the accounting value of the capacity at the start of
the first period ending after 1 April 2002, less any debits or
credits given under paragraph 9.
Company A pays £500,000 for syndicate capacity in the accounting period ended 31 December 1999. It amortises the capacity at 20% per annum on a straight-line basis. It deducts £100,000 in the accounts for each of the periods ended 31 December 2000 and 31 December 2001. These amounts are added back in the Case I computation. The written down value at the start of the period ended 31 December 2002 is £300,000. It deducts £100,000 in these accounts and is entitled to a tax deduction for this amount (FA02/SCH29/PARA9 (5)). In the period ended 31 December 2003 it sells the capacity for £350,000. It is entitled to a deduction of £50,000 (£350,000 proceeds - (£500,000 original cost - £100,000 IP debit)).
Company B acquires the same amount of capacity and amortises it
in the same way. However, it disposes of it for £600,000.
Overall it will be taxed on a profit of £100,000. This is made
up of £600,000 - £400,000 (the original cost
£500,000 less £100,000 IP debit given in APE 2002) =
£200,000 profit in APE 2003.
As Company B had a debit of £100,000 in APE 2002, the
net effect is tax on £100,000, which equals the commercial
profit (£600,000 proceeds less £500,000 original
cost).
If Company C had acquired the capacity in APE 31 December 1996 and had wholly written it off by the start of APE 31 December 2002, it would have no writing down allowance in APE 2002. It would be taxed on a profit of £100,000 on disposal in APE 2003 (£600,000 less original cost £500,000). Alternatively, if Company C disposed of the capacity for £350,000, it would get a deduction of £150,000 (£350,000 less original cost £500,000).