Now back in the UK, and with a functioning computer again, I’ve been digging a little further into the other IP proposals in the HM Treasury Corporate Tax reform document, and looking at the review of the intangibles tax regime published by HMRC – see earlier post for the patent box proposals.
consultation
29
Nov 10
UK: consultation on IP tax reform published
HM Treasury have published the consultation document on IP tax reform, including R&D tax credits – quick thoughts below the cut, more details when I get back from the US next week.
25
Aug 10
EU: consultation on taxing cross-border royalties
Following the report on the functioning of the Interest & Royalties Directive over a year ago, the EU has now launched a consultation on the Directive, looking to clarify existing legislation on taxation of cross-border royalties (and interest) between associated companies and extending benefits of that legislation to a wider range of companies.
2
Jul 10
OECD invites comments on transfer pricing of intangibles
The OECD has identified transfer pricing issues pertaining to intangibles as a key area of concern to governments and taxpayers, due to insufficient international guidance in particular on the definition, identification and valuation of intangibles for transfer pricing purposes.
The OECD is now considering starting a new project on the Transfer Pricing Aspects of Intangibles which could result in a revision of Chapters VI and VIII of the TPG (which deal with intangibles) and is looking for comments on these issues.
22
Jun 10
Budget and tax and IP, oh my
So, what did the budget do for IP? Well, left it mostly alone – for now at least. The swings and roundabouts of corporate tax changes and other such matters will affect IP-related businesses in the same way as they affect all businesses, but the budget releases are fairly light on IP specific material.
24
Feb 10
UK: further CFC slides published
HM Treasury have released the slides from yesterday’s (February 23rd) stakeholder event - more detail to follow once I’ve got free of a 10 day case in court!
9
Feb 10
UK: IP exit tax proposals
The discussion document on controlled foreign companies produced by HM Treasury at the end of January includes proposals for a variation on the UK exit tax to apply for intellectual property assets moved overseas.
26
Jan 10
UK: CFC discussion document published
HM Treasury has published the discussion document on the future of taxation of controlled foreign companies. Of particular interest to IP are the questions on how they should treat overseas companies with IP, proposing to distinguish between those that actively manage the IP and those that passively receive it. The effect would be to ensure that UK parent companies are not taxed on the profits of IP holding subsidiaries in certain circumstances (to be defined!)
The document simply asks questions at this point, rather than suggesting any particular line of thought. In particular, it seeks responses on what constitutes active management of IP – this is likely to be an interesting area of discussion, as many of the characteristics of active management would seem to reflect well-managed investment IP activities as well.
9
Dec 09
UK: Pre-Budget Report IP
The UK Pre-Budget Report today had a couple of IP moments – overall potentially useful, but really just not trying hard enough. It’s another missed opportunity, doing little or nothing to support the majority of IP-focussed business.
Continue reading →
2
Dec 10
UK: IFS dubious about patent box benefits
The IFS has released its comments on the consultation over the patent box. They have concerns that EU laws would mean that companies could benefit from the patent box without having associated real activity in the UK.