530. Disposals of know-how.

Income tax is chargeable on the full amount of profits arising in a tax year1 where consideration is received by a person for the disposal of know-how2, or for giving, or wholly or partly fulfilling, an undertaking (whether or not legally enforceable) which is given in connection with such a disposal, and restricts or is designed to restrict any person's activities in any way3. The person liable for the tax is the person receiving the consideration4. The profits so chargeable are the amount of the consideration, less any expenditure incurred by the recipient wholly and exclusively in the acquisition