Corporation Tax Act 2009

Chapter 5 U.K. Calculation of tax written-down value

742 Asset written down on accounting basis U.K.

(1) For the purposes of this Part, the tax written-down value of an intangible fixed asset to which section 729 (writing down on accounting basis) applies is the cost of the asset recognised for tax purposes, less the total net debits brought into account for tax purposes previously in respect of the asset.

(2) For the purposes of subsection (1) the cost of the asset recognised for tax purposes is the same as the amount of the expenditure on the asset that is capitalised for accounting purposes.

(3) Subsection (2) is subject to any adjustments required by this Part or [F1 Part 4 of TIOPA 2010] (provision not at arm's length).

(4) For the purposes of subsection (1) “the total net debits brought into account for tax purposes previously in respect of the asset”, means the total debits so brought into account, less the total credits so brought into account (if any).

(5) In the case of an asset that has been the subject of a part realisation, this section is subject to section 744.

(6) In the case of an asset that has been subject to adjustment on a change of accounting policy, this section is subject to Chapter 15 (adjustments on a change of accounting policy).

Textual Amendments

F1 Words in s. 742(3) substituted (with effect in accordance with s. 381(1) of the amending Act) by Taxation (International and Other Provisions) Act 2010 (c. 8), s. 381(1), Sch. 8 para. 145(1), (2) (with Sch. 9 paras. 1-9, 22)

743 Asset written down at fixed rate U.K.

(1) For the purposes of this Part, the tax written-down value of an intangible fixed asset in respect of which an election has been made under section 730 (writing down at fixed rate: election for fixed-rate basis) is the cost of the asset recognised for tax purposes, less any debits brought into account for tax purposes previously in respect of the asset under section 731 (writing down at fixed rate: calculation).

(2) For the purposes of subsection (1), the cost of the asset recognised for tax purposes is the same as the amount of the expenditure on the asset that is capitalised for accounting purposes.

(3) Subsection (2) is subject to any adjustments required by this Part or [F2 Part 4 of TIOPA 2010] (provision not at arm's length).

(4) In the case of an asset that has been the subject of a part realisation, this section is subject to section 744.

(5) In the case of an asset that has been subject to adjustment on a change of accounting policy, this section is subject to Chapter 15 (adjustments on change of accounting policy).

Textual Amendments

F2 Words in s. 743(3) substituted (with effect in accordance with s. 381(1) of the amending Act) by Taxation (International and Other Provisions) Act 2010 (c. 8), s. 381(1), Sch. 8 para. 145(1), (2) (with Sch. 9 paras. 1-9, 22)

744 Effect of part realisation of asset U.K.

(1) The tax written-down value of an intangible asset that has been the subject of a part realisation is determined as follows.

(2) Immediately after the part realisation the tax written-down value of the asset is—

where—

WDVB is the tax written-down value of the asset immediately before the part realisation,

AVA is the accounting value of the asset immediately after the part realisation, and

AVB is the accounting value immediately before the part realisation.

(3) Subsequently, the tax written-down value of the asset is determined in accordance with section 742 or 743, but subject to subsections (4) and (5).

(4) The cost of the asset recognised for tax purposes is the sum of—

(a) the tax written-down value in accordance with subsection (2), and

(b) the cost recognised for tax purposes of subsequent expenditure on the asset that is capitalised for accounting purposes.

(5) Only credits and debits brought into account for tax purposes after the part realisation are taken account of.

(6) If there is a further part realisation, subsections (1) to (5) apply again.

(7) If there is a subsequent change of accounting policy affecting the asset, Chapter 15 (adjustments on change of accounting policy) applies.