Corporation Tax Act 2009 section 900F

Special rule: section 900C or 900D case

Section 900F sets out how to calculate the adjusted acquisition cost of an intangible fixed asset that is restricted because it was derived from, or replaced, a pre-Finance Act 2002 asset (the second and third cases for restricted assets).

• Where an intangible fixed asset is restricted under the second or third case (sections 900C or 900D), the company is treated as having acquired it for an adjusted amount rather than its actual cost
• The adjusted amount is calculated by taking the actual (or deemed) acquisition cost and deducting a just and reasonable proportion of the "notional deduction amount" attributable to each relevant other asset from which the restriction arises
• The notional deduction amount depends on the circumstances: it may be the market value of the relevant other asset at the time the restricted asset was acquired, the market value when it was first acquired by a company on or after 1 July 2020, or a recursive calculation where the relevant other asset would itself have been subject to this same adjustment
• If the deduction produces a negative figure, the adjusted amount is treated as nil — meaning the company cannot claim a negative acquisition cost

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