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Posted Thu, 21 Apr 2022 05:37:54 GMT by Amazo
Hi, Hope you are fine. I would highly appreciate if you can answer the following questions in chronological order; Question 1: If a UK Limited company decides to sell its registered trademark and registered design to another company by transferring the ownership, will that company be subject to Corporation Tax/Capital Gains Tax or any other tax on the income made by selling the trademark and design? Question 2: Will your answer to Question 1 be SAME if the sole owner and sole director of the company is either UK resident or Non UK-Resident? Thanks in advance.
Posted Wed, 04 May 2022 09:08:45 GMT by HMRC Admin 19

You can refer to HMRC's Corporate Intangibles Research and Development Manual at CIRD10000 onwards for more information.

CIRD10000 - Intangible assets regime: contents

If the company is resident in the UK, any tax would be due in the UK. If the company is registered in a foreign country and resident there, any tax would be due in that territory. If the company has dual residence, the relevant tax authorities would reach an agreement about taxing rights. If there is a tax treaty between the countries in question, that must also be considered. You can find more information on UK treaties with other countries here:

 Tax treaties 

The director's personal tax residence status is not relevant.

Thank you.

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