27
Jan 09

UK: R&D spend increases

Spending on R&D by the biggest UK R&D companies rose by 6% in 2007 (to £21.6bn) according to figures published on Monday by the Department for Innovation, Universities and Skills.

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22
Jan 09

UK: more R&D incentives called for

The BioIndustry Association’s Bioscience 2015 Review & Refresh document today called for further tax (and other) incentives for biotechnology in the UK, noting that the original Bioscience 2015 vision (published in 2003) “looks somewhat over-optimistic”.

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22
Jan 09

HMRC+IT=WTF

It took HMRC 19 days to figure out that there was a problem and, three days later, they still don’t know how to deal with it.  The problem is, of course, IT-related.  In this case, the online self-assessment system for individuals is still merrily allowing people to opt to have underpaid tax recovered through their PAYE code rather than hand over a cheque to HMRC.  This option was supposed to end on 30 December but the IT system at HMRC refuses to accept that and no-one’s figured out where in the code the off-switch for this option is.

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22
Jan 09

VAT: exam marking software not exempt

In RM Education plc v HM Revenue & Customs [2009] UKVAT V20911 (decision published 9 January 2009), the VAT Tribunal confirmed that exam marking software & associated services do not qualify for the VAT exemption for education.  

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22
Jan 09

US: IRS focus on university IP

From IP Finance: via Tech Transfer E-News comes news that the IRS is to pay increased attention to the tax status of revenue-generating activities of universities – including income from their IP licences.


21
Jan 09

HMRC: updates to CIRD manual – larger SMEs etc

HMRC published a number of changes to the Corporate Intangibles Research and Development (CIRD) manual on January 16th.  Most of the updates are minor changes, but there is some useful substantive guidance added on the changes brought in on 1 August 2008 regarding larger SMEs, dealing with a company moving from large to SME status as a result.

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16
Jan 09

USA: new regulations on cost sharing arrangements

 

On December 31, 2008, the IRS issued temporary regulations for cost sharing arrangements on shared development of intangible assets by related parties, to take effect for arrangements which are put in place from January 5, 2009.

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15
Jan 09

If at first you don’t succeed

HMRC are expected to start targeting IP in transfer pricing enquiries this year, having been forced to back down over plans to widen the extent to which they can tax the IP income of foreign subsidiaries of UK companies.  Possible new penalties – of at least 10% of the tax lost as a result of insufficient transfer pricing – are expected to be introduced in the ongoing powers and penalties review.  Transfer pricing enquiries can be expensive: GlaxoSmithKline’s 14 year transfer pricing dispute with the US tax authority ended in a payment reputed to be around $3.4bn.

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14
Jan 09

US: Amazon loses sales tax case over affiliates

 

Amazon has lost the latest round in its attempt to get the state of New York to back down on a new law requiring out-of-state online companies to collect sales tax from customers in the state.  Sales tax collection in a state is generally required by companies with sufficient connection with that state – but just what constitutes a connection varies from state to state.

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