The UK 'Patent Box'

The recent PBR announced a UK Patent Box regime for taxing royalty income at a reduced 10% corporate tax rate to be applicable from 2013. It has received mixed reviews from UK industry so far. The shape and detail of the new regime is awaiting discussions with stakeholders. But meanwhile a similar incentive already exists in six EU jurisdictions. A bald comparison of the preferential tax rates offered is misleading as each jurisdiction has its own special features summarised in the Table at the end of the article and no doubt the Government will be taking these factors into account when devising the UK's system. At the end of the day the choice of jurisdiction for UK groups, whether UK or abroad, will depend on their own specific circumstances.