Part 4: Income tax, corporation tax and capital gains tax Section 33: Intangible fixed assets: goodwill etc. Background note
This measure supports the government’s objective to have a fair tax system for all.
	Under Part 8 CTA 2009 companies obtain corporation tax relief when expenditure on goodwill and intangible assets is recognised in the accounts. This relief is therefore available to companies who acquire a business directly by purchasing its trade and assets. It is not available to companies who acquire shares in the vendor company.
	This section removes this relief with regard to the purchase of goodwill and other intangible assets closely related to goodwill. It will restrict the ability of companies to reduce their corporation tax profits following a merger or acquisition and removes this artificial incentive to buy assets rather than shares.
	The measure does not impose any restriction in respect of intangible assets apart from goodwill and the other specified "relevant assets". Investment expenditure on intellectual property and other intangible assets will continue to get relief under Part 8.