Legal News

The importance of IP law in IP tax transactions

Published on: 11 July 2011
Published by a LexisNexis Tax expert

Table of contents

  • Original news
  • What are the main implications of this case for the tax treatment of IP?
  • What key principles emerge for distinguishing between capital and revenue receipts in the context of IP?
  • What does this case mean for determining whether IP constitutes new or old assets, within or outside of the intangible fixed assets regime?
  • What can be learned from the tribunal’s interpretation of the mini-GAAR in the intangible fixed assets regime in the context of this case?
  • What can be learned from the tribunal’s interpretation of the unallowable purpose rule in the loan relationships regime in the context of this case?
  • What does this case mean for tax lawyers advising their clients in relation to transactions involving IP?

Article summary

Tax analysis: The importance of getting intellectual property law advice on an IP tax transaction is underlined by the recent tax-avoidance case of Iliffe News & Media Ltd v Revenue and Customs Commissioners, says Anne Fairpo, of Atlas Chambers.

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