UK tax aspects of cross-border IP structuring—development and acquisition of IP

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

Practice notes

UK tax aspects of cross-border IP structuring—development and acquisition of IP

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

Practice notes

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The UK government has consistently sought to position the UK as one of the world's most attractive environments for innovation and enterprise. This has involved developing a number of tax benefits incentivising innovative businesses at both investor and business level and for businesses at each stage of their life cycle. These tax benefits include:

•
R&D tax reliefs
•
patent box
•
business asset disposal relief (formerly entrepreneurs' relief)
•
capital allowances for purchases of:
1. ◦
  knowhow
2. ◦
  patents, and
3. ◦
  plant and machinery
•
venture capital trusts
•
the enterprise investment scheme, and
•
the seed enterprise investment scheme

This Practice Note sets out the UK perspective on various tax issues that should be taken into account in deciding how an innovative 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

Jurisdiction(s):

United Kingdom

Key definition:

Acquisition definition

What does Acquisition mean?

A supply of goods, or a transaction treated as a supply of goods, which involves the removal of goods from one EU member state to another.

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