Commentary

A4.438 Payments of a capital nature

Administration and compliance

A4.438 Payments of a capital nature

A4.438 Payments of a capital nature

Tax is not deducted from the purchase price of patent rights from a person resident in the UK. Such a person is chargeable to income tax or corporation tax on the purchase price, spread evenly over six years1.

Subject to any exemption under a double taxation agreement, a person not resident in the UK who sells the rights in a UK patent to a UK resident is chargeable to tax on the sale price, and the purchaser must deduct tax (in accordance with the rules of ITA 2007, s 910) from

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