Corporation Tax Act 2010 section 357OG

Northern Ireland element: credits where roll-over relief involved

Section 357OG sets out how to calculate the Northern Ireland element of a realisation credit on an intangible fixed asset where roll-over relief was previously claimed, meaning the asset's cost for tax purposes was reduced when a gain on an earlier asset was rolled over into it.

• Where an intangible asset's tax cost was reduced by roll-over relief from a previous asset disposal, a special five-step calculation replaces the general rule for determining the Northern Ireland element of any realisation credit
• The credit is split into three components: the portion relating to accumulated net tax debits on the new asset, the portion attributable to the rolled-over gain from the old asset, and any remaining balance — each with its own method for identifying the Northern Ireland element
• The Northern Ireland element of the rolled-over gain component is determined by reference to what the Northern Ireland proportion of the old asset's credit would have been had roll-over relief not applied
• The total Northern Ireland element is the sum of the Northern Ireland portions from the three components, ensuring that gains originating from both the old and new assets are properly apportioned to the Northern Ireland rate