Corporation Tax Act 2009 section 1308

Expenditure brought into account in determining value of intangible asset

Section 1308 deals with how revenue expenditure on research and development is treated for corporation tax purposes when that expenditure has been capitalised as part of the value of an intangible asset in the company's accounts.

  • Revenue expenditure on R&D that has been capitalised into an intangible asset in the accounts can still be claimed as a tax deduction against profits, including under the R&D tax relief rules in Part 13 of CTA 2009
  • Where the expenditure is both capitalised in the intangible asset value and claimed as a tax deduction, no further deduction is allowed for the writing down of the portion of the intangible asset's value that relates to that expenditure
  • The tax deduction is not available if the expenditure has already been deducted in a previous accounting period, or if the company has already benefited from an R&D tax relief under Part 13 for a previous period in respect of the same expenditure
  • "Intangible asset" takes its ordinary accounting meaning, and "research and development" is defined by section 1138 of Corporation Tax Act 2010

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