Commentary

D1.1203D Anti-avoidance

Corporate tax
Corporate tax | Commentary

D1.1203D Anti-avoidance

Corporate tax | Commentary

D1.1203D Anti-avoidance

The rules include anti avoidance provisions, which are briefly outlined below.

The first counters the conferment of irrelevant exclusivity under an agreement1. It is not intended to apply if there is a commercially reasonable choice about exclusivity, and the two parties agree to opt for one because the licensee recognises that it will qualify for the patent box.

The second counters qualifying items being incorporated into a product with the main intent of generating RIPI2. Again it is intended to apply where a choice is made for tax purposes when there is no, or insignificant, commercial rationale. It is not

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