David O’Keeffe

This Practice Note explains how to calculate a company's profits eligible for relief under the post-1 July 2016 patent box rules. The Practice Note sets out the eight-step process involved and examines key issues, including the streaming of relevant IP income (RIPI) and deductions for routine returns and marketing assets returns. It also covers the application of the R&D fraction, which is applied to meet the BEPS requirement that patent box benefits be linked to R&D levels. It concludes by describing how patent box relief is given. This Practice Note was produced in partnership with David O'Keeffe of Aiglon Consulting.

This Practice Note explains what a company can do with a relevant IP loss (RIPL). A company in the early stages of IP developments may have a RIPL rather than relevant IP profits, as a result of its patent box calculation and will not benefit from patent box relief. Instead, the company must set off the RIPL against other of its, or its group’s, profits for the current or future accounting periods. This Practice Note was produced in partnership with David O'Keeffe of Aiglon Consulting.

This Practice Note sets out the key features of the patent box regime, an elective regime providing for an effective 10% rate of corporation tax on worldwide profits attributable to qualifying patents and similar intellectual property rights. It considers the meaning of qualifying IP rights; the development condition; a qualifying company; an exclusive licence; and a group. It covers elections and how the regime applies to partnerships and cost-sharing arrangements. This Practice Note was produced in partnership with David O'Keeffe of Aiglon Consulting.