Section 929 — Corporation Tax Act 2009: Apportionment where property sold together

Apportionment where property sold together 929 1 Any reference in this Part to the sale of property includes the sale of that property together with other property.

2 In this section— references to property include know-how, and references to the sale of property include the disposal of know-how.

3 For the purposes of subsection (1), all property sold as a result of one bargain is to be treated as sold together even though—

a separate prices are, or purport to be, agreed for separate items of that property, or b there are, or purport to be, separate sales of separate items of that property.

4 If an item of property is sold together with other property, then, for the purposes of the charges under sections 908 and 912—

a the net proceeds of the sale of that item are treated as being so much of the net proceeds of the sale of all the property as, on a just and reasonable apportionment, is attributable to that item, and b the expenditure incurred on the provision or purchase of that item is treated as being so much of the consideration given for all the property as, on a just and reasonable apportionment, is attributable to that item.