(1) In this section -
"EEA Agreement" means the Agreement on the European Economic Area signed at Oporto on 2 May 1992, as adjusted by the Protocol signed at Brussels on 17 March 1993;
"EEA state" means a state which is a Contracting Party to the EEA Agreement;
"income from a qualifying patent" means any royalty or other sum paid in respect of the user of the invention to which the qualifying patent relates, including any sum paid for the grant of a licence to exercise rights under such patent, where that royalty or other sum is paid -
(a) for the purposes of activities which -
(i) would be regarded, otherwise than by virtue of paragraph (b) or (c) of section 445(7) or section 446, as the manufacture of goods for the purpose of relief under Part 14, or
(ii) would be so regarded if they were carried on in the State by a company,
but, as respects a royalty or other sum paid on or after the 23rd day of April, 1996, where the royalty or other sum exceeds the royalty or other sum which woul
…