{
  "url": "https://openlegislation.uk/income-tax-earnings-and-pensions-act-2003/section-459n1",
  "json_url": "https://openlegislation.uk/income-tax-earnings-and-pensions-act-2003/section-459n1.json",
  "legislation": "ukpga/2003/1",
  "legislation_title": "Income Tax (Earnings and Pensions) Act 2003",
  "legislation_url": "https://openlegislation.uk/income-tax-earnings-and-pensions-act-2003",
  "path": "section/459n1",
  "kind": "section",
  "number": "459",
  "heading": "Transfer of intellectual property by controlled company",
  "text": "(1) For the purposes of this Chapter where a research institution has control of a company, a transfer of intellectual property from the company is to be treated as a transfer from the research institution.\n(2) For the purposes of this Chapter where two or more research institutions together have control of a company, a transfer of intellectual property from the company is to be treated as a transfer from those research institutions.\n(3) In this section “control” means control within the meaning given by sections 450 and 451 of CTA 2010.",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "Pt. 7 Ch. 4A inserted (with effect in accordance with s. 20(5)-(7) of the amending Act) by Finance Act 2005 (c. 7), s. 20(1)"
    },
    {
      "type": "F",
      "label": "F2",
      "text": "Words in s. 459(3) substituted (with effect in accordance with s. 1184(1) of the amending Act) by Corporation Tax Act 2010 (c. 4), s. 1184(1), Sch. 1 para. 389 (with Sch. 2)"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2003/1/section/459n1",
    "retrieved_at": "2026-10-29T09:18:42.395488+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."
}