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Contents

Official guidance
Corporate Intangibles Research and Development Manual

CIRD10100 · Intangible assets: introduction

  • CIRD10101 · Background
  • CIRD10105 · Chronology of CTA09 reforms
  • CIRD10110 · Overview of CTA09/PART8 tax rules
  • CIRD10115 · Link with accountancy
  • CIRD10116 · Simple example of taxation entries derived from figures in accounts
  • CIRD10120 · Capital versus revenue distinction no longer crucial
  • CIRD10125 · Expenditure linked to assets and to non capitalised expenditure
  • CIRD10130 · Disallowance of sums charged in the accounts
  • CIRD10140 · Commencement of the Part 8 regime: pre-FA 2002 assets
  • CIRD10145 · Assets outside CTA09 rules: location of guidance
  • CIRD10150 · Royalties from new or pre-FA 2002 assets
  • CIRD10160 · Related parties
  • CIRD10170 · Reinvestment relief
  • CIRD10175 · Reinvestment relief: transitional arrangements
  • CIRD10180 · Reinvestment relief: example
  • CIRD10190 · Groups of companies
  • CIRD10200 · International aspects
  • CIRD10210 · Finance leasing
  • CIRD10220 · Fungible assets
  • CIRD10230 · Avoidance
  • CIRD10240 · Valuation issues
  1. Intangible assets: introduction: contents
  2. Intangible assets: introduction: fungible assets

CIRD10220 | Intangible assets: introduction: fungible assets

From HM Revenue & Customs · Corporate Intangibles Research and Development Manual

Some assets are of a type that can be dealt in without identifying the particular assets involved. Examples would include some agricultural production rights arising from EU rules, such as milk quota. A holding of a number of identical units of a fungible asset count as a single asset for the purposes of the corporate intangible assets regime.

There are special commencement rules for fungible assets to ensure that additional units of a type of asset already held at 1 April 2002 can come within the regime, in spite of the general rule mentioned above, and to counter attempts to turn pre-FA 2002 assets outside the regime into assets within the regime by sale and repurchase. See CIRD11760 onwards.

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