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HMRC internal manual

Capital Allowances Manual

Know-how: Receipts: Trading receipt treatment

ICTA88/S531 (1)

Sometimes the normal rules for Schedule D do not treat a receipt for know-how as a trading receipt. If they do not a payment received by a trader for know-how which is not a disposal value or already chargeable as a revenue receipt is treated as a trading receipt.

This means that consideration received for the disposal of know-how in a continuing trade is either:


a.treated as a revenue receipt under general law, or

b. brought to account as a disposal value in the capital allowance computation, or

c. if neither (a) nor (b) applies treated as a trading receipt.