Corporation Tax Act 2009 section 929

Apportionment where property sold together

Section 929 deals with how sale proceeds and costs should be split when know-how or patent rights are sold together with other property as part of a single transaction.

• A sale of property within this Part includes a sale of that property bundled together with other property, and references to property and sales extend to know-how and disposals of know-how
• Where multiple items of property are sold under a single bargain, they are treated as sold together — even if separate prices are agreed or separate sales purport to take place for individual items
• When property is sold together with other property, the net sale proceeds attributable to each item must be determined on a just and reasonable apportionment of the total proceeds
• Similarly, the expenditure on acquiring or providing each item must be determined on a just and reasonable apportionment of the total consideration given for all the property sold together