Allens Arthur Robinson: Publication: Focus: Tax disputes involving s25-90 interest deductions – ATO lose challenge to deductions on funding royalty stream acquisition
Australia: Article – royalty stream funding deductions case
Leave a reply
Monthly Archives: March 2011
Spain: Article on illegality of digital tax
France/Spain: EU referral to ECJ on telecoms taxes
Experiment: Podcast #1
I’ve been thinking about doing a podcast for a while, and decided to experiment with a podcast on the highlights of the Budget for IP. It should stream in the browser, let me know if you want to hear more in future.
UK: The Budget & IP
Headlines:
- R&D tax relief increased for SMEs to 200% in 2011 and 225% in 2012
- R&D tax credit repayment no longer restricted by PAYE/NICs
- R&D large company relief to include sub-contractor costs
- Patent box to have more consultation – still 10%, still patents only, applying from 1 April 2013
- Capital allowances for short-life assets now 8 years – useful for capital expenditure that doesn’t qualify for R&D allowances, and exceeds the annual investment allowance
- Reductions in corporate tax rate useful to all companies
- Enterprise Zone changes could be attractive
- 24 new University Technical Colleges to be established
UK: budget art
Whilst I’m writing up the Budget changes, this amuses me – the Budget in black and white, via Wordle
South Africa: article on R&D tax incentive
See: http://www.moneywebtax.co.za/moneywebtax/view/moneywebtax/en/page259?oid=57207&sn=Detail&pid=1
Seems similar to UK R&D tax incentive, but possibly easier to spot qualifying R&D.
Israel: tax incentive for M&A in high-tech companies
See: http://www.jpost.com/Business/Commentary/Article.aspx?id=213334
Allows acquiring company to write off net value of IP in acquired company over 5 years – both acquirer and acquired must be companies incorporated and managed/controlled in Israel, so has very limited application globally.
Israel: article on tax incentive for investors in high-tech companies
See: http://www.jpost.com/Business/Commentary/Article.aspx?id=211342
Allows investor to write off investment up to NIS 5m over three years against income in Israel – open to foreign investors with Israeli income as well as Israeli investors.
UK: Budget tomorrow (March 23rd)
Immediate updates on IP-related Budget thoughts will be posted on twitter – a more detailed update will be posted here when I’ve had time to read through the inevitable small print that arrives after the Chancellor sits down!
What’s expected on IP tax (at least):
- an update on CFCs – should have some IP content to it
- update on the consultation on IP tax and R&D which closed on February 22nd
- more information on the patent box (in the consultation update)
There might be more …