Anti-avoidance

Incorporation of qualifying items

Licenses conferring exclusive rights

Tax advantage scheme

Calculating relevant IP profits: streaming, alternative method

Generally

Mandatory streaming conditions

Method of allocation

Commencement arrangements

Deduction

Development requirement

Condition A

Condition B

Condition C

Condition D

Qualifying development

Losses

Allocation of set-off amount within a group

Carry-forward of set-off amount

Company ceasing to carry on trade

Generally

Payments between group members in consequence of section 357EB

Set-off against profits of another trade of a company

Transfer of a trade between group members

Miscellaneous

Cost sharing arrangements

Patent rights

Qualifying company

Condition A

Condition B

Condition C

Requirements

Qualifying intellectual property

Development condition

Patent rights

Products which have the benefit of marketing protection or data protection

Scope

Relevant IP profits from qualifying intellectual property

Steps required to calculate relevant IP profits