Corporation Tax Act 2009 section 879I

Restrictions on debits: no business or no qualifying IP assets acquired

Section 879I restricts the tax deductions (debits) a company can claim in respect of certain intangible assets (called "relevant assets") acquired on or after 1 April 2019, where those assets were not acquired as part of a genuine business acquisition that included qualifying intellectual property.

• The restriction applies when a company acquires a relevant asset outside of a business acquisition — for example, purchasing a standalone intangible asset
• The restriction also applies when a relevant asset is acquired as part of a business acquisition, but no qualifying IP assets are acquired for continuing use in that business
• Where the restriction applies, no tax deductions can be claimed for amortisation or write-downs of the asset, nor for adjustments arising from changes in accounting policy
• If a debit arises on the disposal or realisation of the restricted asset, it is treated as a non-trading debit, meaning it cannot be offset against trading profits