The following Corporation Tax guidance note Produced by Tolley provides comprehensive and up to date tax information covering:
Major changes to the patent box regime were made by FA 2016 to bring it into line with the outcome of the OECD’s recommendations on tackling harmful tax practices and preferential IP regimes. See the Patent box tax regime ― overview guidance note for details. The commentary in this guidance note applies to the calculation of relevant IP profits where the company is not a new entrant, with no new qualifying IP rights for accounting periods beginning before 1 July 2021.
The patent box legislation sets out seven steps that should be followed in order to calculate the qualifying IP profits to which the reduced rate of corporation tax may be applied. These steps are set out in the Calculating relevant IP profits ― existing claimants with no new IP rights guidance note, which should be read in conjunction with this note.
At step 5 of the qualifying IP profits calculation, a qualifying company is able to adopt a simpler, more formulaic approach to determine how much of the qualifying residual profit (QRP) represents profit from qualifying IP rights and how much relates to brand and marketing assets. The brand and marketing profit element (the small claims amount) must be removed from
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The substantial shareholding exemption (SSE) provides a complete exemption from the liability to corporation tax on the gains generated from qualifying disposals of shares and interests in shares by qualifying companies. Conversely, if losses are generated by the disposal and the SSE conditions are
‘Hold-over’ relief allows for the deferral of a gain that would otherwise arise in relation to a disposal. No capital gains tax (CGT) is due in respect of the disposal, but the base cost of the asset for the transferee for the purpose of a future disposal is reduced by an amount equal to the gain
IntroductionUK resident individuals who are non-UK domiciled can benefit from the remittance basis of taxation. The remittance basis allows for relief from UK taxation for non-UK sources of income which are not brought in (or remitted) to the UK. A remittance is any money or other property which is,
Business asset disposal relief (previously known as entrepreneurs’ relief) is a capital gains tax (CGT) relief that allows business owners with chargeable gains on qualifying business assets to pay CGT at a rate of 10%. For disposals made on or after 11 March 2020, the relief is available on up to
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