Section 357NH — Corporation Tax Act 2010: Payments and receipts in respect of intangible assets

Payments and receipts in respect of intangible assets 357NH 1 No deduction is allowed in calculating the profits attributable to the company's NI RE for royalties paid, or other similar payments made, by the NI RE to any other part of the company in respect of the use of intangible assets held by the company.

2 But a deduction is allowed in calculating the profits attributable to the NI RE for any contribution by the NI RE to the costs of creation of an intangible asset.

3 No receipt is to be brought into account in calculating the profits attributable to the NI RE for royalties or other similar amounts received from any other part of the company in respect of the use of intangible assets held by the company for the purposes of the NIRE.

4 But a receipt is to be brought into account in calculating profits attributable to the NI RE for any contribution received by the NI RE in respect of the costs of creation of an intangible asset.

5 In this section “intangible asset”—

a includes any intellectual property (as defined in section 712(3) of CTA 2009),

and b subject to that, has the meaning it has for accounting purposes.