Part 8Intangible fixed assets

Chapter 14Miscellaneous provisions

Assets ceasing to be or becoming chargeable intangible assets

863Asset becoming chargeable intangible asset

(1)

This section applies if an asset becomes a chargeable intangible asset in relation to a company—

(a)

on the company becoming UK resident,

(b)

in the case of a company that is not UK resident, on the asset beginning to be heldF1—

(i)

for the purposes of a trade carried on by the company in the United Kingdom through a permanent establishment,

F2(ii)

for the purposes of a trade carried on by the company of dealing in or developing UK land,

(iii)

for the purposes of a UK property business carried on by the company, or

(iv)

for the purposes of enabling the company to generate other UK property income (within the meaning given by section 5(6)), or

(c)

on the asset ceasing to be held for the purposes of a mutual trade or business.

(2)

This Part applies as if—

(a)

the company had acquired the asset immediately after it became a chargeable intangible asset in relation to the company, and

(b)

had done so for its accounting value at that time.

F3(3)

But subsection (2)(b) is subject to section 863A.