CIRD47010 | Intangible assets: international issues: introduction

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

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.