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!
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.
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.
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.
The Treasury has today announced that the Chancellor will provide a further update on tax and innovation in the Pre-Budget Report on Wednesday 9 December 2009, and released slides (link to 1.6Mb powerpoint presentation) from a presentation to a business-government forum in late October.