The following Corporation Tax guidance note Produced by Tolley in association with Anne Fairpo provides comprehensive and up to date tax information covering:
This guidance note outlines some tax considerations in relation to international intellectual property planning. The objective of intellectual property planning is usually to minimise tax on royalty income, eg by holding the intellectual property in a group company which is not resident in the UK.
In addition to tax matters, practical matters must also be considered such as where intellectual property is legally registered.
Royalties may be subject to a low rate of tax in a number of countries, including:
offshore jurisdictions such as Jersey or Guernsey which have low headline rates of tax (0%), as does Ireland (12.5%)
Malta which has a low effective rate of tax (6% after payment of dividends)
many European countries, including Belgium, Netherlands, Cyprus, Ireland and Luxembourg, have special rates of tax applicable to royalties and other income from intellectual property
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