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HMRC internal manual

Corporate Intangibles Research and Development Manual

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Core computational rules: taxable credits: receipts recognised as they accrue: general

CTA09/PART8/S721

This provision encompasses all kinds of receipts from the exploitation of intangibles assets within Part 8, apart from the proceeds from realising assets (for which see CIRD13010). The receipts within section 721 will mostly be of a revenue nature and in those circumstances there will often be no significant difference between how the receipt would be brought to account under Part 8 and how it would be treated if it were outside Part 8. So whether or not a particular receipt is within section 721 will often be an issue of no great practical consequence.

The taxable credit for a period of account in respect of a receipt of this nature will normally be the same as the accounting gain relating to that receipt, as recognised in a company’s profit and loss account for that period.

The statute makes provision for the accounting gain to be subject to any adjustments for tax purposes (see CIRD12030). In practice, tax adjustments in this context are likely to be unusual but examples would be:

  • a transfer pricing adjustment to increase the taxable credit (see CIRD47060), or
  • the exclusion of an exempt grant (see CIRD13030 below on grants generally).