Corporation Tax Act 2009

876 Original asset subject to fixed-rate writing down

(1) This section applies if—

(a) the change of accounting policy results in an intangible fixed asset of the company that was treated as one asset (“the original asset”) in the earlier period being treated as two or more assets (“the resulting assets”) in the later period, and

(b) an election under section 730 (writing down at fixed rate: election for fixed-rate basis) has been or is subsequently made in respect of the original asset.

(2) That election has effect—

(a) in relation to the original asset, for periods up to and including the earlier period, and

(b) in relation to each of the resulting assets, for the later period and subsequent periods.

(3) The tax written-down value of each resulting asset at the beginning of the later period (“the relevant time”) is—

where—

• WDVE is the tax written-down value of the original asset at the end of the earlier period,

• AVL is the accounting value of the asset in question at the beginning of the later period, and

• TAVL is the sum of the accounting values of all the resulting assets at the beginning of that period.

(4) After the relevant time the cost recognised for tax purposes for each resulting asset is the sum of—

(a) the tax written-down value given by subsection (3), and

(b) the cost recognised for tax purposes of any subsequent expenditure on the asset that is capitalised for accounting purposes.

(5) After the relevant time the tax written-down value for each resulting asset is determined taking account only of subsequent credits and debits.