UK Tax Opinion on Royalties

I need a qualified UK tax adviser (CTA, ACA, ACCA or equivalent) to give me a concise yet technically robust view on the accounting and corporation-tax treatment of unpaid trademark royalties covered by an existing Trademark Licence Agreement.

Scope
• Review three short documents I will share: the Trademark Licence Agreement, a Deed of Waiver executed this year, and a brief background note.
• Address two specific issues:
1. Can royalties that accrued in 2023 be recognised in my 2024 accounts under the terms of the licence?
2. If challenged by HMRC, would a benchmark memorandum prepared now constitute adequate contemporaneous evidence to support the royalty rate?

Deliverables
• A formal letter on your firm’s letterhead setting out the conclusions in plain English.
• An accompanying tax memo (2-3 pages is sufficient) citing the relevant legislation, HMRC guidance, and any key case law or accounting standards (FRS 102 / IFRS as applicable) that underpin your conclusions.

Please keep the opinion focused and practical; I am not looking for an extensive treatise—just clear, defensible answers with the necessary statutory references. Indicate any additional assumptions you have had to make.

I will forward the documents as soon as we start so you can turn the work around quickly.