Commentary

D4.808 Intellectual property

Corporate tax
Corporate tax | Commentary

D4.808 Intellectual property

Corporate tax | Commentary

D4.808 Intellectual property

The provisions in this article apply only to companies where an election has not been made for exemption for the profits of a foreign permanent establishment (D4.801). For details of the double tax relief provisions that generally apply equally to companies and individuals see Division E6.4.

Specific provisions apply when giving double taxation relief on non-trading credits in respect of intangible fixed assets1. These provisions broadly mirror the loan relationship rules (D4.807), so that double taxation relief is maximised for foreign tax suffered on non-trading intangibles credits by allowing the taxpayer flexibility in offsetting non-trading debits in relation

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