Article 24 - Amortisation of Intangible Fixed Assets

(1) A QFC Entity shall be entitled to a deduction for the amortisation of an Intangible Fixed Asset acquired for the purpose of its Licensed Activity of an amount equal to the amortisation charged in its accounts.
(2) Subject to Article 24(4), in the case of an Internal Intangible Fixed Asset, the amortisation deduction under Article 24(1) shall not exceed the amount of taxable income generated from charges for the use, licence or exploitation of the asset.
(3) An Internal Intangible Fixed Asset is any Intangible Fixed Asset acquired from a Connected Person by a QFC Entity and used (to any extent) to generate Taxable Profits by granting rights to use, licensing or otherwise exploiting the Intangible Fixed Asset.
(4) Where an Internal Intangible Fixed Asset is acquired from a Connected Person by a QFC Entity for the purposes of both:
(a) generating Taxable Profits by granting rights to use, licensing or otherwise exploiting the Internal Intangible Fixed Asset; and
(b) use by that QFC Entity to carry on its Licensed Activity, excluding activities described in Article 24(4)(a),
the Internal Intangible Fixed Asset shall be deemed to be two distinct notional assets for the purposes of Article 24(2), reflecting an asset used solely for the purposes described in Article 24(4)(a) and an asset used solely for the purposes described in Article 24(4)(b) and Article 24(2) shall only operate to limit an amortisation deduction under Article 24(1) in respect of the notional asset used solely for the purposes described in Article 24(4)(a).
(5) For the purposes of Article 24(4), the amortisation deduction available under Article 24(1) in respect of the Internal Intangible Fixed Asset shall be apportioned between the two notional assets described in Article 24(4) on a basis which is demonstrated to the Tax Department as being just and reasonable.
Amended (as from 18th June 2014)