Corporation Tax Act 2009 section 879D

Pre-FA 2019 relevant asset: the first case

Section 879D defines the first of four cases in which an intangible asset is classified as a "pre-FA 2019 relevant asset," preserving earlier restrictions on goodwill relief for assets acquired and held during specific transitional periods.

• An asset qualifies as a pre-FA 2019 relevant asset if the company acquired or created it between 8 July 2015 and 31 March 2019
• The asset must also have been a chargeable intangible asset in relation to the company at some point between 29 October 2018 and 31 March 2019
• This rule preserves the effect of the former section 816A restriction, which denied goodwill-related debits on certain intangible assets acquired from 8 July 2015 onwards
• Both conditions — the acquisition window and the holding window — must be met for the asset to fall within this first case