Commentary

A4.437 Spreading of royalties over several years

Administration and compliance

A4.437 Spreading of royalties over several years

A4.437 Spreading of royalties over several years

Royalties or other sums received in respect of the use of a patent may be spread for the purposes of both basic and higher rate tax over a number of years1. If the use extends over a period of six years or more, the person receiving the payment may require that the tax payable by him by reason of this receipt shall not exceed the amount which would have been payable if the royalty or sum had been paid in six equal yearly instalments, the last one on the date when payment, in

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