Corporation Tax Act 2009 section 900E

Special rule: section 900B case

Section 900E limits the tax debits a company can claim in respect of a restricted intangible fixed asset that is restricted under the section 900B rules, by adjusting the cost at which the company is treated as having acquired the asset.

• Where a company is the first to acquire a pre-1 July 2020 intangible asset on or after that date, and the asset is restricted under section 900B, the company is treated as having acquired the asset at no cost — meaning no tax debits can arise from that acquisition cost.
• Where the company is not the first to acquire the asset on or after 1 July 2020, it is instead treated as having acquired the asset for the "adjusted amount", calculated as the actual acquisition cost minus the market value of the asset on the date it was first acquired by any company on or after 1 July 2020.
• If the market value on that first post-1 July 2020 acquisition date exceeds the actual consideration paid, the adjusted amount is nil — so the company cannot be treated as having acquired the asset for a negative figure.
• The adjustment applies specifically for the purposes of Chapter 3 (debits in respect of intangible fixed assets), Chapter 15 (adjustments on change of accounting policy), and Chapter 5 (calculation of tax written-down value) insofar as Chapter 5 supports Chapters 3 and 15.