Sale or lease of Intellectual property

Tax implications of selling or leasing Intellectual property

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We have a client who has personally created intellectual property(IP) or "know-how". He considers this IP to have considerable value although the exact value is up for debate.

He has a company which he is the sole shareholder and director and is considering either leasing the IP to the company for a monthly return or selling it to the company.

From reading  ITTOA 2005 my understanding is thus:-

If he leases to the company he will be subject to an income tax charge under s.579, s.527 of ICTA 1998 I believe is not relevant as no lump sum is involved.

If he sells it to the company there is no  income tax charge under s.583 as there is an exemption under s.584 (4) a.

Have I read this correctly? It seems strange he would be able to dispose of such a valuable asset tax free. For reference he is talking about figures of £20-£30k a month.

Would he/we need to consider if any of the sale proceeds are in relation to goodwill and subject to a tax charge under s.462 of CAA 2001.

Thanks for any advice given.

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