{
  "url": "https://openlegislation.uk/corporation-tax-act-2010/section-357GCZF",
  "json_url": "https://openlegislation.uk/corporation-tax-act-2010/section-357GCZF.json",
  "legislation": "ukpga/2010/4",
  "legislation_title": "Corporation Tax Act 2010",
  "legislation_url": "https://openlegislation.uk/corporation-tax-act-2010",
  "path": "section/357GCZF",
  "kind": "section",
  "number": "357GCZF",
  "heading": "Treatment of income in connection with formation of CSA etc",
  "text": "(1) Where—\n(a) a company receives a payment in consideration of its entering into a cost-sharing arrangement, and\n(b) the company holds a qualifying IP right granted in respect of the invention or holds an exclusive licence in respect of such a right,\na just and reasonable amount of the payment is to be treated as relevant IP income of the company.\n(2) Where—\n(a) a company that is a party to a cost-sharing arrangement receives a payment from a person in consideration of its agreeing to that person becoming a party to the arrangement (whether in place of the company or in addition to it), and\n(b) any party to the arrangement holds a qualifying IP right in respect of the invention or holds an exclusive licence in respect of such a right,\na just and reasonable amount of the payment is to be treated as relevant IP income of the company.\n(3) Where—\n(a) a company that is a party to a cost-sharing arrangement receives a payment from another party to the arrangement in consideration of its agreeing to that party becoming entitled to a greater share of the income attributable to the invention or acquiring additional rights in relation to the invention, and\n(b) any party to the arrangement holds a qualifying IP right in respect of the invention or holds an exclusive licence in respect of such a right,\na just and reasonable amount of the payment is to be treated as relevant IP income of the company.",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "Pt. 8A inserted (with effect in accordance with Sch. 2 paras. 7, 8 of the amending Act) by Finance Act 2012 (c. 14), Sch. 2 para. 1(1)"
    },
    {
      "type": "F",
      "label": "F2",
      "text": "Ss. 357GC-357GCZF substituted for s. 357GC (with effect in accordance with s. 23(5) of the amending Act) by Finance (No. 2) Act 2017 (c. 32), s. 23(3)"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2010/4/section/357GCZF",
    "retrieved_at": "2026-10-29T09:10:29.433154+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}