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(ii) be treated for the purposes of sections 81(2)(m), 237 and 238 as if it were a royalty paid in respect of the user of a patent.

(4) Notwithstanding section 81(2), where any sum paid or valuable consideration given by a person carrying on a trade or profession is chargeable to tax in accordance with subsection (2), the sum paid or the value of the consideration given, as the case may be, may be deducted as an expense in computing for the purposes of Schedule D the profits or gains of that person’s trade or profession, as the case may be—

(2) Subject to section 81(2)(n), subsection (1) shall not apply to so much of any payment as consists of expenditure incurred by a company to the extent that it is incurred on shares acquired by the company and given by it as consideration for goods or services, or to an employee or director of the company.

(ii) a company not so resident which carries on a trade in the State through a permanent establishment if, in relation to the trade the interest gives, or as the case may be the royalties give, rise to a deduction under section 81 or 97 or relief under Part 8,

(d) Where a Revenue officer is satisfied that the amount of expenditure claimed under paragraph (c) would not have been disallowed under section 81 if the specified person had provided the services directly to the qualifying company by carrying on a trade or profession chargeable to tax under Case I or Case II, then a Revenue officer shall issue a notification to the qualifying company specifying the amount of expenditure that shall be allowed as a deduction under paragraph (a).

(iv) on receipt of a claim under subparagraph (iii) a Revenue officer shall make a determination on an amount that is equal to the expenditure that would not have been disallowed as a deduction under section 81 if the specified person had provided the services directly to the qualifying company by carrying on a trade or profession chargeable to tax under Case I or Case II,

(i) any interest expense which gives rise to a deduction under section 81 or relief under Part 8,

(1) Notwithstanding section 81, in computing the profits or gains of any trade, there shall be allowed to be deducted as expenses any fees paid or expenses incurred in obtaining for the purposes of the trade the grant of a patent or an extension of the term of a patent.

(2) Notwithstanding anything in section 81, any amount, computed in accordance with generally accepted accounting practice, charged to the profit and loss account of a company, for the period of account which is the same as the accounting period, in respect of expenditure, for the purposes of a trade carried on by the company, on the purchase of an emissions allowance shall be allowed to be deducted as expenses in computing the amount of the profits or gains of the company to be charged to tax under Case I of Schedule D for the accounting period.

Notwithstanding anything in section 81, in computing the amount of the profits or gains of any trade, there shall be allowed to be deducted as expenses any fees paid or expenses incurred in obtaining for the purposes of the trade the registration of a trade mark or the renewal of registration of a trade mark.

(c) the value of any sum received in payment of a debt shall be treated as not taken into account in the computation to the extent that a deduction has been allowed in respect of that sum under section 81(2)(i).

(3) In computing for tax purposes the profits or gains of the trade or profession in any period after the change, there may be deducted a sum equal to any amount proved during that period to be irrecoverable in respect of any debts credited in computing for tax purposes the profits or gains for any period before the change (being debts the benefit of which was assigned to the persons carrying on the trade or profession after the change), in so far as the total amount proved to be irrecoverable in respect of those debts exceeds any deduction allowed in respect of them under section 81(2)(i) in a computation for any period before the change.