Corporation Tax Act 2009 section 900N

Debits in respect of a single asset comprising restricted assets

Section 900N explains how to calculate the cost of a single fungible asset that is made up of restricted intangible fixed assets, for the purpose of determining allowable tax debits.

• This section applies where a company holds a single combined asset that is itself classified as a restricted asset because it comprises individual restricted assets pooled together as fungible assets.
• For the purpose of calculating tax debits, the company is treated as having acquired the single combined asset for a cost equal to the total of the individual deemed acquisition costs of each restricted asset within it.
• The deemed acquisition cost of each component restricted asset is determined under the relevant chapters of Part 8 of the Corporation Tax Act 2009, as defined by section 900E(6).
• This ensures that the correct, potentially limited, tax debit is calculated when restricted assets are grouped together as a single fungible asset.