Commentary

B3.607 Patent rights controlled sales

Business tax
Business tax | Commentary

B3.607 Patent rights controlled sales

Business tax | Commentary

B3.607 Patent rights controlled sales

Where a person has acquired patent rights as a result of a transaction, or a series of transactions, between connected persons1, any balancing charge arising on his subsequent disposal of those rights is to take into account the amount of any expenditure incurred on those rights by any of the connected persons2.

The purchaser's qualifying expenditure may be restricted where patent rights are purchased from a connected person, or where the sole or main benefit which appears to have been derived from a sale of patent rights, or a series of transactions including such a sale,

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