Corporation Tax Act 2009 section 879L

Meaning of relevant business and third party acquisition

Section 879L defines two key terms used in the restrictions on tax debits when a company acquires goodwill or certain other intangible assets from an individual or a firm: "relevant business" and "third party acquisition".

• The "relevant business" is the business (or part of a business) to which the intangible asset in question is linked, as identified under section 879A
• A "third party acquisition" occurs when the transferor acquires an asset from a company to which they are not a related party, or from a non-corporate person to whom they are not connected
• An acquisition does not qualify as a "third party acquisition" if its main purpose (or one of its main purposes) is for any person to obtain a tax advantage
• An acquisition that took place between 8 July 2015 and 31 March 2019 is also excluded from being a "third party acquisition", because a general restriction on relief was in force during that period