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HMRC internal manual

Corporate Intangibles Research and Development Manual

Intangible assets within CTA09/PART8: FA02 rule exceptions: royalties: outline


Because CTA09/PART8 at most only changes the time when royalties are brought to account for corporation tax (see CIRD11700) they are immediately brought within CTA09/PART8, regardless of whether the intangible asset in respect of which they are paid or received falls within the scope of CTA09/PART8.

The royalties which are brought within CTA09/PART8 in this way are those which:

  • fall within the definition of a royalty in CIRD11710 
  • arise at the time described in CIRD11720