Related Commentary  Related HMRC Manuals

908(1)  The charge to corporation tax on income applies to profits arising where consideration is received by a company–

(a)for the disposal of know-how, or

(b)for giving, or wholly or partly fulfilling, an undertaking which–

(i)is given in connection with a disposal of know-how, and

(ii)restricts or is designed to restrict any person's activities in any way.

908(2)  For the purposes of subsection (1)(b), it does not matter whether or not the undertaking is legally enforceable.

908(3)  Subsection (1) is subject to the exceptions in section 909.

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