Amortisation of patent and copyright acquisition - periodic deduction with sale proceeds adjusting remaining deductions and taxable excess. Capital expenditure on acquisition of patent rights or copyrights used in business is amortised by applying an appropriate fraction (one over the number of relevant previous years) of the acquisition cost in each of a specified multi year period beginning with the year of expenditure (or business commencement). If rights end or are sold, tax consequences depend on whether sale proceeds equal, exceed, or are less than the unallowed acquisition cost, producing either denial of further deductions, an allowable deduction for the deficit, or chargeability of excess proceeds as business income; part disposals prorate remaining deductions over unexpired years.
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Provisions expressly mentioned in the judgment/order text.
Amortisation of patent and copyright acquisition - periodic deduction with sale proceeds adjusting remaining deductions and taxable excess.
Capital expenditure on acquisition of patent rights or copyrights used in business is amortised by applying an appropriate fraction (one over the number of relevant previous years) of the acquisition cost in each of a specified multi year period beginning with the year of expenditure (or business commencement). If rights end or are sold, tax consequences depend on whether sale proceeds equal, exceed, or are less than the unallowed acquisition cost, producing either denial of further deductions, an allowable deduction for the deficit, or chargeability of excess proceeds as business income; part disposals prorate remaining deductions over unexpired years.
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