Corporation Tax Act 2010 section 357OK

Fungible assets

Section 357OK deals with how fungible (interchangeable) intangible fixed assets held by a Northern Ireland company are classified when some were acquired before and some after the relevant commencement date.

• Fungible intangible fixed assets are interchangeable assets that tax law treats as a single notional asset rather than tracking each one individually.
• Pre-commencement assets and post-commencement assets must be treated as two separate pools, even though they are otherwise interchangeable — they are regarded as assets of different kinds.
• A pooled single asset made up entirely of pre-commencement assets retains its status as a pre-commencement asset.
• A pooled single asset made up entirely of post-commencement assets is treated as an asset that is not a pre-commencement asset.