Commentary

B5.316 Royalties and other income from intellectual property

Business tax
Business tax | Commentary

B5.316 Royalties and other income from intellectual property

Business tax | Commentary

B5.316 Royalties and other income from intellectual property

Subject to the deductions listed below, income tax is charged on royalties and other income from intellectual property arising in the tax year, so far as it is not included in the profits of a trade or profession1. The charge is on the person receiving or entitled to the income2. Where the income arises outside the UK, the special rules in ITTOIA 2005, ss 829–845 (Pt 8) apply3. In Braithwaite's4 the Special Commissioner held that the taxpayer was assessable on all the royalties paid by a company to which he had assigned intellectual

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