Commentary

B5.339 Winding up of a company

Business tax
Business tax | Commentary

B5.339 Winding up of a company

Business tax | Commentary

B5.339 Winding up of a company

The corporate tax treatment of intangible assets, including patents, acquired or created on or after 1 April 2002 is set out in the corporate intangible regime as detailed in Division D1.6. The commentary below relates to pre-FA 2002 assets where it refers to corporation tax.

A company may be liable to corporation tax on profits from the sale of patent rights:

  1.  

    •     if it is not resident in the UK and does not trade in the UK through a permanent establishment, or

  2.  

    •     if the profit arises to it in a fiduciary or representative capacity

In

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