Part 2 U.K. Charge to corporation tax: basic provisions

Chapter 4 U.K. Non-UK resident companies: chargeable profits

Rules about deductions U.K.

31 Restriction on deductions: payments in respect of intangible assets U.K.

(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)).