Tax issues and incentives arising from assignment and licensing of IP
Produced in partnership with Anne Fairpo of Temple Tax Chambers
Tax issues and incentives arising from assignment and licensing of IP

The following Tax practice note Produced in partnership with Anne Fairpo of Temple Tax Chambers provides comprehensive and up to date legal information covering:

  • Tax issues and incentives arising from assignment and licensing of IP
  • Assignment of IP
  • Corporate intangibles rules
  • Individuals and other non-corporates, and pre-1 April 2002 IP assets
  • Stamp duty
  • Licensing of IP
  • Royalties
  • Restrictions for those exploiting IP developed by others
  • VAT
  • Cross-border—businesses
  • More...

IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s withdrawal from the EU. At this point in time (referred to in UK law as ‘IP completion day’), key transitional arrangements come to an end and significant changes begin to take effect across the UK’s legal regime. This document contains guidance on subjects impacted by these changes. Before continuing your research, see Practice Note: What does IP completion day mean for Tax?

STOP PRESS relating to pre-1 April 2002 assets: The Finance Act 2020 contains provisions that allow companies to claim corporation tax relief for intangible fixed assets (IFAs) created before 1 April 2002 when acquired from related parties on or after 1 July 2020 (subject to transitional provisions to preserve the rules for such IFAs held immediately before 1 July 2020 and specific anti-avoidance provisions). A new regime also applies to fungible assets from this date. For more, see News Analyses: Finance Bill 2020—Reform of tax treatment of pre-Finance Act 2002 intangible fixed assets and Spring Budget 2020—Tax analysis—Intangibles reform.

The UK has two approaches to taxing IP transactions:

  1. the corporate intangibles tax rules: these apply to IP created or acquired by a company on or after 1 April 2002 (unless the asset was acquired from a related party that owned the asset

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