Corporation Tax Act 2009 section 856

Assets acquired or realised together

Section 856 requires individual values to be allocated to intangible fixed assets that are acquired or disposed of together with other assets as part of the same bargain.

• When assets are acquired or disposed of under a single bargain, they are treated as acquired or disposed of together, even if separate prices are agreed or separate transactions purport to take place for each asset.
• Where a company allocates values to individual assets in accordance with generally accepted accounting practice (GAAP), those values must be accepted for tax purposes.
• Where no GAAP-compliant values have been allocated to assets acquired together, the total expenditure must be split between the assets on a just and reasonable basis.
• Where assets are disposed of together, the total proceeds must similarly be apportioned between the individual assets on a just and reasonable basis.