Corporation Tax Act 2009 section 900L

Realisation of fungible assets: pre-FA 2002 assets and restricted assets

Section 900L establishes the order in which different categories of fungible assets are treated as being disposed of when a company realises (sells or otherwise disposes of) a fungible asset that spans more than one tax category.

• This section applies when a company realises a fungible asset that would otherwise form part of a single asset spanning more than one category (pre-FA 2002, restricted, or standard intangible fixed assets)
• Pre-FA 2002 assets (those held before the intangible fixed assets regime took effect) must be treated as disposed of first, before restricted assets or standard intangible fixed assets
• Restricted assets must be treated as disposed of next, before standard intangible fixed assets
• The effect is a strict priority ordering: pre-FA 2002 assets first, then restricted assets, then standard intangible fixed assets last