Commentary

B5.309 Lump sums as income―traders

Business tax
Business tax | Commentary

B5.309 Lump sums as income―traders

Business tax | Commentary

B5.309 Lump sums as income―traders

The corporate tax treatment of intangible assets, including intellectual property, acquired or created on or after 1 April 2002 is set out in the corporate intangible regime as detailed in Division D1.6.

Where a trader receives a lump sum payment for the use of intellectual property, but remains able to exploit the subject matter of the intellectual property to his own account, the lump sum receipt is generally treated as income. A classic case is that of Rolls-Royce Ltd's 1. The taxpayer company manufactured aircraft engines. In the course of its business it developed a substantial body of

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