UK tax aspects of cross-border IP structuring—exploitation of IP

Produced in partnership with Graham Samuel-Gibbon of Taylor Wessing LLP
Practice notes

UK tax aspects of cross-border IP structuring—exploitation of IP

Produced in partnership with Graham Samuel-Gibbon of Taylor Wessing LLP

Practice notes
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This Practice Note sets out the UK perspective on various tax issues that should be taken into account in deciding how an innovative IP business with international or global ambition might be structured. The points below are Generic and effectively assume a blank canvas; restructuring an existing IP-Ownership set-up will obviously require a tailored approach (especially in the context of joint ventures or consortia), but the following points will still be likely to need consideration.

As part of the UK's bid to become one of the world's most attractive environments for innovation and Enterprise, several tax benefits are available to incentivise the UK-based development and exploitation of IP, including:

  1. R&D tax reliefs

  2. the patent box

  3. business asset disposal relief (formerly entrepreneurs' relief)

  4. amortisation deductions for purchases of intellectual property by companies

  5. for smaller companies:

    1. venture capital trusts

    2. the enterprise investment scheme, and

    3. the seed enterprise investment scheme

The focus of this Practice Note is on businesses

Graham Samuel-Gibbon
Graham Samuel-Gibbon

Graham is Head of the UK Tax and Incentives team at Taylor Wessing. He is an international tax specialist who advises domestic and multinational clients on a wide range of transactional and advisory tax matters. Graham regularly works with FTSE 100 and Future Global 100 companies.

He guides clients through stock and asset/business acquisitions and disposals, cross border tax structuring, UK inbound and outbound investment, joint ventures and reorganisations.

He also advises on tax issues relating to the development, ownership and exploitation of intellectual property rights, with a particular focus on the life science and technology sectors.

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Jurisdiction(s):
United Kingdom
Key definition:
ACT definition
What does ACT mean?

Association of Corporate Treasurers.

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