[371DJ Exclusion: trading profits (IP condition)]
Taxation (International and Other Provisions) Act 2010 (2010 c 8) | Legislation

[371DJ  Exclusion: trading profits (IP condition)]

[(1)     This section applies for the purposes of section 371DF(1)(d).

(2)     The IP condition is met unless—

(a)     the CFC's assumed total profits include amounts arising from intellectual property held by the CFC (“the exploited IP”),

(b)     all or parts of the exploited IP were—

(i)     transferred (directly or indirectly) to the CFC by persons related to the CFC at times during the relevant period, or

(ii)     otherwise derived (directly or indirectly) at times

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