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Corporation Tax Act 2009

Section 859: Asset ceasing to be chargeable intangible asset: deemed realisation at market value

2200.This section gives a market value deemed realisation and reacquisition rule in three particular cases. It is based on paragraph 108 of Schedule 29 to FA 2002.

2201.Subsection (2) lists the cases to which the section applies. In each, without changing ownership, the asset ceases to be a “chargeable intangible asset”. That is, any gain on realisation would cease to fall within the intangible fixed assets rules (see section 741).

2202.There is an obverse rule in section 863 which applies when an asset becomes a chargeable intangible asset.

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