The consultation on the corporate intangibles regime promised at the Budget is now available at gov.uk.
It’s not a massive root & branch overhaul – the accounts basis isn’t going anywhere, for example. The focus is on the following:
- exclusion of pre-2002 assets, whether that’s still appropriate and how to value them if they were to enter the regime
- restriction of amortisation on goodwill, whether there’s anything practical that can be done to remove the impact on unregistered IP that’s within goodwill
- de-grouping charges: to what extent they cause problems, can these be resolved
- 4% fixed election for assets which aren’t amortised in the accounts: could it be improved
- what are the benefits to multinationals of holding IP in the UK
- how can the regime be made more cost-effective, suggesting a possible focus on relating amortisation to increased economic activity.