CIRD47010 | Intangible assets: international issues: introduction

Where provisions described

This section of the manual describes certain provisions relevant to the treatment of goodwill and intangible assets under the rules in CTA09/PART8 that have a particular international dimension. Other provisions with an international dimension described elsewhere are listed below.

Provisions described in this section

• asset moving into or out of UK tax net without changing ownership - CIRD47020 and CIRD47030,

• company becomes resident in the UK - CIRD47020,

• asset held by a non-resident company begins to be used in its UK trade carried on through a permanent establishment in the UK - CIRD47020,

• company ceasing to be resident in the UK - CIRD47030,

• asset held by a non-resident company ceasing to be used in its UK trade carried on through a permanent establishment in the UK - CIRD47030,

• deferral of taxable credit arising where company ceases to be resident in the UK - CIRD47040,

• application of transfer pricing rules to goodwill and intangible assets within CTA09/PART8 - CIRD47060.

Provisions described elsewhere

• transfer of overseas trade carried on through a permanent establishment to non- resident - CIRD42040 and CIRD42060,

• transfer of UK trade involving companies resident in different member States - CIRD42030,

• avoidance using cross-border structures - CIRD48140.