Commentary on Sections Overview Chapter 13: Transactions between related parties Section 851: Delayed payment of royalty by company to related party
2185.This section gives a timing rule for the deduction of a royalty paid to a related party. It is based on paragraph 94 of Schedule 29 to FA 2002.
2186.The effect of subsection (2) is to bring approximate symmetry to the timing of the charge on the recipient of the royalty and relief for the payer.