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The tax treatment of intangible fixed assets (IFAs) generally is set out in the Corporate intangibles tax treatment guidance note. There are, however, specific rules for related party transactions.

Where an asset was acquired or created before 1 April 2002, it is referred to as a ‘pre-FA 2002 asset’. Prior to 1 July 2020, pre-FA 2002 assets did not come within the scope of the corporate intangibles regime and instead were (in most cases) dealt with under the capital gains regime. However, for acquisitions made on or after 1 July 2020, any intangible asset acquired by a company will be taxed under the corporate intangibles regime, even if the asset was acquired from a related party. This rule is subject to the existing restrictions that apply to amortisation relief in respect of goodwill and customer-related assets. There are also transitional rules to counter avoidance where a pre-FA 2002 asset is acquired from a related party, which will restrict the tax relief for the acquiring company (see ‘When will an intangible fixed asset be a restricted asset?’ below). In addition,