Part 2Charge to corporation tax: basic provisions

Chapter 4Non-UK resident companies: chargeable profits

Rules about deductions

31Restriction on deductions: payments in respect of intangible assets

1

No deduction is allowed for royalties paid, or other similar payments made, by the permanent establishment to any other part of the non-UK resident company in respect of the use of intangible assets held by the company.

2

This does not prevent a deduction for any contribution by the permanent establishment to the costs of creation of an intangible asset.

3

In this section “intangible asset” has the meaning it has for accounting purposes, and includes any intellectual property (as defined in section 712(3)).