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Legislation
Corporation Tax Act 2010

CHAPTER 2B Relevant IP profits: cases mentioned in section 357A(7): income from new IP

  • Section 357BO Relevant IP profits
  • Section 357BP Meaning of “new qualifying IP right” and “old qualifying IP right”
  • Section 357BQ The modifications
  1. Chapter 2B
  2. Relevant IP profits

Section 357BO | Relevant IP profits

From legislation.gov.uk

(1)Section 357BF applies, with the modifications set out in section 357BQ, for the purposes of determining the relevant IP profits of a trade of a company for an accounting period in a case where—

(a)the accounting period begins before 1 July 2021,

(b)the company is not a new entrant (see section 357A(11)), and

(c)any amount of relevant IP income brought into account as a credit in calculating the profits of the trade for the accounting period is properly attributable to a new qualifying IP right (see section 357BP).

(2)Where it is necessary for the purposes of section 357BF, as applied by this section, to determine the R&D fraction for a relevant IP income sub-stream, the company concerned is to be treated for the purposes of sections 357BLF and 357BLG as if it were a new entrant.

(3)Where section 357BF applies by reason of this section for the purposes of determining the relevant IP profits of a trade of a company for an accounting period, the company may not make a global streaming election for the accounting period under section 357BN(2)(c).

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