An intangible problem

Jitendra Patel considers the complexities of the intangible fixed assets regime and tries to untangle the tax consequences of transactions involving IFAs and partnerships

It has been almost 20 years since the introduction of the intangible fixed assets (IFA) regime (Corporation Tax Act (CTA) 2009 Part 8), which fundamentally changed the corporation tax treatment of goodwill and intangible assets. A large number of updates have been made since then, but some of the rules continue to mystify through their unexpected tax consequences. This article focuses on the anomalous outcomes arising from transactions involving IFAs and partnerships (including limited partnerships and limited liability partnerships).

What is the issue?