Section 357GCZF — Corporation Tax Act 2010: Treatment of income in connection with formation of CSA etc

Treatment of income in connection with formation of CSA etc 357GCZF 1 Where—

a a company receives a payment in consideration of its entering into a cost-sharing arrangement, and b the company holds a qualifying IP right granted in respect of the invention or holds an exclusive licence in respect of such a right, a just and reasonable amount of the payment is to be treated as relevant IP income of the company.

2 Where—

a a company that is a party to a cost-sharing arrangement receives a payment from a person in consideration of its agreeing to that person becoming a party to the arrangement (whether in place of the company or in addition to it),

and b any party to the arrangement holds a qualifying IP right in respect of the invention or holds an exclusive licence in respect of such a right, a just and reasonable amount of the payment is to be treated as relevant IP income of the company.

3 Where—

a a company that is a party to a cost-sharing arrangement receives a payment from another party to the arrangement in consideration of its agreeing to that party becoming entitled to a greater share of the income attributable to the invention or acquiring additional rights in relation to the invention, and b any party to the arrangement holds a qualifying IP right in respect of the invention or holds an exclusive licence in respect of such a right, a just and reasonable amount of the payment is to be treated as relevant IP income of the company.