- removal of income tax relief for individuals paying non-trade patent royalties (s448 ITA 2007). This has been taken out because the Treasury felt it was being misused for tax avoidance – it only applied to individuals who paid patent royalties otherwise than in the course of a trade, so it wasn't often claimed in any case. It affects any individual holding patent licences as an investment – it won't affect anyone owning patents outright, as they would not generally be paying royalties where they own the patent outright.
- £600m towards Research Council infrastructure and facilities for applied R&D – this seems to be new money, although it's not quite clear from the documents released so far.
- And finally, the proposed reduction in corporation tax to 21% in 2014 will benefit any profitable IP companies, although it's not specifically aimed at the sector.
Monday, 10 December 2012
Autumn Statement & IP
Not a lot in last week's Autumn Statement for IP, but I thought I'd cover what was there:
The draft Finance Bill (due to be published tomorrow) should also have details of the proposed 'above the line' (ATL) R&D credit which will replace the current large company R&D tax relief – the key feature of the ATL credit is that it will be repayable to loss-making large companies (at least, in theory – the draft Bill should reveal whether companies are actually likely to get repayments in practice).