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HMRC internal manual

Corporate Intangibles Research and Development Manual

Patent Box : new regime : transfer of trade provisions

CTA10 s357GCA

There are special rules relating to the new regime when there has been a transfer of a trade or a part trade, regardless of whether the companies are part of the same group.  CIRD240160 explains

  • the conditions which need to be met for CTA10/s357GCA to apply

  • the requirements in relation to inheriting any grandfathered status

  • the requirements in relation to inheriting the components of the R&D fraction

-what to include as an acquisition cost (A in the R&D fraction).

To ensure that this section is not overlooked when considering the new regime please follow the link to CIRD240160

CIRD240160 also sets out the rules concerning relevant IP losses when a trade has been transferred for the old and new regimes, which is why it is in the chapter on losses.