Commentary

B5.307 Sources of income or supply

Business tax
Business tax | Commentary

B5.307 Sources of income or supply

Business tax | Commentary

B5.307 Sources of income or supply

For income tax and corporation tax purposes, the source of intellectual property revenue or supply is often regarded as located where the owner or licensor resides. If a trade or profession is carried on in the UK by a UK resident taxpayer and the intellectual property rights flow from the exercise of that trade or profession, it appears that the taxpayer is liable to tax in the UK on worldwide income. Thus in Davies'1 an actress was assessed under the former Schedule D Case II in respect of worldwide earnings. The rigour of this

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