Corporation Tax Act 2009 section 906

Priority of this Part for corporation tax purposes

Section 906 establishes that the intangible fixed assets rules in this Part take priority over other corporation tax rules when determining the amounts to be brought into account.

• When calculating corporation tax on matters covered by this Part (intangible fixed assets), the only amounts to be used are those determined under this Part's rules.
• This priority rule is not absolute — it can be overridden where other legislation specifically indicates a different treatment should apply.
• One notable exception is section 1308 of CTA 2009, which deals with expenditure brought into account when determining the value of an intangible asset.
• Another exception is section 112(5) of TIOPA 2010, which allows a deduction for foreign tax where no tax credit is available against UK tax.