Corporation Tax Act 2009 section 884

Goodwill: time of creation

Section 884 provides a special rule for determining when goodwill is treated as having been created, which affects whether the intangible assets regime applies to it.

• The intangible assets regime (Part 8 of CTA 2009) generally only applies to assets created or acquired on or after 1 April 2002.
• Goodwill is treated as created before 1 April 2002 if the business in question was carried on at any time before that date by the company or a related party.
• In all other cases, goodwill is treated as created on or after 1 April 2002 and therefore falls within the intangible assets regime.
• This rule specifically addresses internally-generated goodwill, where there is no acquisition date to refer to.