Corporation Tax Act 2010 section 357OD

"Realisation credit" and "realisation debit"

Section 357OD defines what counts as a "realisation credit" or "realisation debit" for the purposes of the Northern Ireland corporation tax regime, specifically in relation to gains or losses arising when a company disposes of or otherwise realises an intangible fixed asset used in its trade.

  • A realisation credit or debit is a credit or debit that arises under the intangible fixed assets rules in Part 8 of CTA 2009 when such an asset is realised (for example, sold or written off).
  • The credit or debit must be one that is treated as a trading receipt or trading expense of the company's trade under section 747 of CTA 2009.
  • The credit or debit must not relate to a pre-commencement asset — that is, an intangible fixed asset that was already held before the intangible fixed assets regime came into effect.
  • All three conditions must be met for a credit or debit to qualify as a realisation credit or realisation debit within this Chapter.

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