As noted at ¶702-200, corporation tax is charged on profits from sales of the whole or part of any patent rights as if those profits were income, even though the proceeds are capital in nature. The fact of charging a capital profit as if income runs counter to normal tax principles and a form of spreading of the tax charge operates to mitigate the effect. The detail of the spreading rules depends on whether or not the seller is resident in the UK.
Want to read more?
This content requires a Croner-i Tax and Accounting subscription.