Taxes Consolidation Act 1997 section 769H

Families of products and assets

Section 769H allows a relevant company to apply the Knowledge Development Box provisions to a family of interlinked qualifying assets rather than to each individual asset, where it is not possible to separately identify the expenditure or income attributable to each asset.

• Where a relevant company has a number of qualifying assets that are so interlinked in their use in the specified trade that it would not be possible to identify the overall expenditure on, or overall income from, each individual qualifying asset, the section permits the company to treat those assets as a group.
• A "family of assets" is defined as the smallest grouping of such interlinked qualifying assets for which the related expenditure and income can reasonably be identified.
• The company may opt for the Chapter to apply to a family of assets, in which case all references to qualifying assets throughout the Chapter are read as references to that family of assets.
• The election is available only where it would be reasonable to conclude that it would not be possible to identify the expenditure or income for each asset individually — a merely burdensome allocation is not sufficient.