Corporation Tax Act 2009 section 879C

Restrictions on debits: pre-FA 2019 relevant assets

Section 879C restricts the tax deductions (debits) that a company can claim in respect of certain intangible fixed assets classified as "pre-FA 2019 relevant assets" — broadly, relevant assets held between the announcement of goodwill relief reforms on 29 October 2018 and their implementation on 1 April 2019.

• No amortisation or writing-down debits may be claimed for pre-FA 2019 relevant assets, nor may debits arise on a change of accounting policy in respect of such assets.
• Any debit arising on the disposal or realisation of a pre-FA 2019 relevant asset must be treated as a non-trading debit, meaning it cannot reduce trading profits but instead forms part of a separate non-trading loss calculation.
• The definition of what constitutes a pre-FA 2019 relevant asset is set out in sections 879D to 879H, which describe four separate cases.
• This section preserves the restrictive effect that the former section 816A had on relevant assets during the transitional period between announcement and enactment of the Finance Act 2019 reforms.