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More blasts
Key points
- A restriction applies where the expenditure on relevant assets is more than six times the expenditure on qualifying IP assets.
- A partial restriction will apply if the expenditure incurred by the company exceeds the accounting value used by the transferor.
- Fraction for calculating the partial restriction.
- Changes to the rules apply to accounting periods beginning on or after 1 April 2019.
In the first part of this article ‘Blast from the past’ (Taxation 11 July page 20) we considered some of the full restrictions that may apply to the new intangibles regime. In the second part we consider some of the further partial restrictions (CTA 2009 s 879M et seq).
When the partial restrictions apply
Partial restrictions on debits may apply if the company acquires the relevant asset concerned on or after 1 April 2019 as part of the acquisition of a business the company also...
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