Corporation Tax Act 2009 section 762

Realisation and reacquisition

Section 762 deals with how reinvestment relief applies when a company sells an intangible fixed asset and later buys it back.

• If a company realises (sells or disposes of) an intangible fixed asset and later reacquires the same asset, the tax rules treat it as a completely different asset
• This means the reacquired asset is not regarded as the same asset that was previously disposed of for reinvestment relief purposes
• The practical effect is that reinvestment relief can still be claimed on the original disposal, even though the company has bought the same asset back
• This provision accommodates situations such as a change in business plans, where a company may need to reacquire an asset it previously sold