I’ve been asked a few times since last Thursday’s referendum what the implications might be for the UK’s R&D and Patent Box regimes. In terms of negative implications, the answer is that there really shouldn’t be any. Both of these reliefs are UK domestic reliefs contained within UK tax legislation and they do not rely [...]
HMRC published draft legislation on 9 December covering some of the changes needed to make the UK's Patent Box regime OECD/BEPS compliant. Unfortunately, there is an important error in the drafting. This concerns the provisions that relate to whether or not IP transferred (or licensed) between connected parties on or after 2 January 2016 can [...]
I recently blogged on the publication of Countering Harmful Tax Practices More Effectively, Taking into Account Transparency and Substance, the final report on Action 5 of the OECD BEPS project. In that blog I suggested that any revised Patent Box regime in the UK was likely to be so complex – in order to comply [...]
Earlier this month the OECD published its final report on Action 5 of its BEPS project. The report - niftily titled Countering Harmful Tax Practices More Effectively, Taking into Account Transparency and Substance includes a section on the Substantial activity requirement in the context of IP regimes. In other words, the requirements for the design [...]