Corporation Tax Act 2009 section 883

Assets treated as created or acquired when expenditure incurred

Section 883 establishes that, for the purposes of the intangible fixed assets regime, an asset is treated as created or acquired at the time the expenditure on it is incurred, and provides rules for splitting assets where expenditure straddles key dates.

• An intangible asset is treated as created or acquired on or after 1 April 2002 to the extent that expenditure on its creation or acquisition is incurred on or after that date.
• For acquisitions, further date boundaries apply: expenditure incurred on or after 1 July 2020, during the period 1 April 2002 to 30 June 2020, or during the period 19 March 2020 to 30 June 2020 each triggers a separate treatment.
• Where only part of the expenditure on an asset falls within the intangible fixed assets regime, the asset is split into two notional assets — one within the regime and one governed by the older tax rules — with costs apportioned on a just and reasonable basis.
• These rules are subject to specific exceptions for goodwill, assets representing non-qualifying expenditure, and assets representing production expenditure on films.