Corporation Tax Act 2009 section 879F

Pre-FA 2019 relevant asset: the third case

Section 879F defines the third scenario in which an intangible fixed asset is classified as a pre-Finance Act 2019 relevant asset, focusing on newly created assets whose value derives from an older asset that has preserved status.

  • An asset created on or after 29 October 2018 and acquired from a related party on or after 1 April 2019 is a pre-FA 2019 relevant asset if its value derives wholly or partly from another asset that meets the preserved status condition
  • Where only part of the asset's value derives from the preserved status asset, the acquired asset is split into two notional assets โ€” one representing the derived value (treated as pre-FA 2019) and one representing the remainder (not so treated)
  • Value can be considered to derive from another asset in broad circumstances, including where assets have been merged, divided, changed in nature, or where rights or interests in assets have been created or extinguished
  • The preserved status condition that the other asset must satisfy is set out separately in section 879G, which supplements this provision

Access full legislation.And much more.

By becoming a member, your team gets full access to Tax World research tools and source-backed tax resources.