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Chapter CIRD220230

Document Cited in Related
Vincent
Published date11 March 2016
Record NumberCIRD220230
CTA10/S357CC(8) & (9) Head 4

Head 4 is any income payable to the company from an infringement or alleged infringement of the company’s qualifying IP rights held at the time of the infringement or alleged infringement.

Head 5

Head 5 is income that is received by way of insurance, compensation or other damages which, although not falling under head 4 as receipts for a direct infringement of qualifying IP rights, is nonetheless to be treated as relevant IP income.

Such receipts must either be:

  • in respect of qualifying items whose sale would produce income falling within head 1 , or
  • be an amount in respect of lost income which, if it had been received, would have represented relevant IP income.
Qualifying company

Infringement or other compensation may not be received until after the patent has expired or been disposed of. If so then under S357B(3) the company may still be treated a qualifying company for the purposes of the beneficial CT rate even if it has no other patents by the time the income falls to be taxed. The event in...

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