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Contents

Official guidance
Corporate Intangibles Research and Development Manual

CIRD220150 · Patent Box: relevant IP profits: relevant IP income: sub contents

  • CIRD220160 · Patent Box: relevant IP profits: relevant IP income: overview
  • CIRD220170 · Patent Box: relevant IP profits: relevant IP income: head 1: sales income
  • CIRD220180 · Patent Box: relevant IP profits: relevant IP income: head 1: sales income: packaging
  • CIRD220190 · Patent Box: relevant IP profits: relevant IP income: head 1: sales income: examples
  • CIRD220200 · Patent Box: relevant IP profits: relevant IP income: head 2: licence fees and royalties
  • CIRD220210 · Patent Box: relevant IP profits: relevant IP income: head 2: licence fees and royalties: examples
  • CIRD220220 · Patent Box: relevant IP profits: relevant IP income: head 3: proceeds of realisation
  • CIRD220230 · Patent Box: relevant IP profits: relevant IP income: heads 4 and 5: infringement income, damages, insurance proceeds or other compensation
  • CIRD220240 · Patent Box: relevant IP profits: relevant IP income: heads 4 and 5: infringement income, damages, insurance proceeds or other compensation: example
  • CIRD220250 · Patent Box: relevant IP profits: relevant IP income: notional royalties: IP derived income
  • CIRD220251 · CTA10/s357BHA Patent Box: Notional Royalties: How to calculate the ‘appropriate percentage’
  • CIRD220252 · Patent Box: relevant IP profits: relevant IP income: notional royalties: examples
  • CIRD220255 · Patent Box: relevant IP profits: relevant IP income: notional royalties: leasing income
  • CIRD220260 · Patent Box: relevant IP profits: relevant IP income: notional royalties: summary of calculations
  • CIRD220270 · Patent Box: relevant IP profits: relevant IP income: notional royalties: transfer pricing principles: assumptions
  • CIRD220280 · Patent Box: relevant IP profits: relevant IP income: excluded income
  • CIRD220290 · Patent Box: relevant IP profits: relevant IP income: mixed sources of income
  • CIRD220300 · Patent Box: relevant IP profits: relevant IP income: medical use claims
  • CIRD220305 · Patent Box: relevant IP profits: relevant IP income: method and process patents
  • CIRD220310 · Patent Box: relevant IP profits: relevant IP income: software: introduction
  • CIRD220315 · Patent Box: relevant IP profits: relevant IP income: software: income earned
  • CIRD220320 · Patent Box: relevant IP profits: relevant IP income: software: examples
  • CIRD220325 · Patent Box: relevant IP profits: relevant IP income: patented software: further examples
  1. Patent Box: relevant IP profits: relevant IP income: sub contents
  2. Patent Box: relevant IP profits: relevant IP income: overview

CIRD220160 | Patent Box: relevant IP profits: relevant IP income: overview

From HM Revenue & Customs · Corporate Intangibles Research and Development Manual

CTA10/S357BH

Relevant IP income is the income derived from the exploitation of qualifying IP rights as defined in S357BH. S357BH (12) ensures that a company is regarded as holding a qualifying IP right if it holds an exclusive licence of the right.

In many cases ‘RIPI’ and ‘relevant IP income’ will be synonymous. However RIPI is defined in 357BH(1) and in order for relevant IP income to be RIPI it must be included in the heads of income of the trade. RIPI could never include finance income which is specifically excluded by s357BG. RIPI cannot include any income not taken into account in computing trading profits.

The legislation splits the exploitation of IP rights into five different heads:

CIRD220170Head 1 - sales income
CIRD220200Head 2 - licence fees
CIRD220220Head 3 - proceeds of sale
CIRD220230Head 4 - damages for infringement
CIRD220240Head 5 - other compensation

If a company derives some of its income from the exploitation of the patented invention but the income does not fall into any of the five heads, it may be able to deem some of that income to be RIPI as a ‘notional royalty’ for the patented item (CIRD220250).

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