Corporation Tax Act 2010 section 357BNC

Global streaming election

Section 357BNC explains how the Patent Box profit calculation rules are simplified when a company elects to treat all of its qualifying intellectual property income as a single global stream, rather than splitting it into separate sub-streams for each individual IP right or product.

• Where a company makes a global streaming election under section 357BN(2)(c), all qualifying IP income is pooled into one single stream instead of being divided into individual sub-streams for each IP right
• The multi-step calculation process in section 357BF is simplified by removing the steps that split income into sub-streams and re-aggregate them, so that deductions, the routine return figure, and the marketing assets return figure are all applied to the single combined stream
• All references to "sub-stream" throughout the relevant calculation sections — including those for routine return, marketing assets return, notional and actual marketing royalties, the R&D fraction, and small claims — are replaced with "stream" to reflect the single-stream approach
• References to expenditure and IP rights that previously related to the specific sub-stream are broadened to refer to any qualifying IP right to which income in the single stream is attributable