Skip to content

Intellectual Property (IP)

All Related Articles

patent box regimes in Europe 2022 patent box Europe EU intellectual property tax regime IP

Patent Box Regimes in Europe

Patent box regimes (also referred to as intellectual property, or IP, regimes) provide lower effective tax rates on income derived from IP. Most commonly, eligible types of IP are patents and software copyrights. Currently, 13 of the 27 EU member states have a patent box regime.

3 min read
Both inbound and outbound foreign direct investment (FDI) are critical to sustaining supply chain resiliency and reducing economic risks

How FDI Adds Value to Supply Chains

Although the dispersion of our supply chains throughout the world has been scrutinized in recent years, both inbound and outbound foreign direct investment are critical to sustaining supply chain resiliency and reducing economic risks for both firms and investors.

5 min read
Compare 2021 patent box regimes in Europe (Patent box Europe data). Explore intellectual property box regimes in the EU Europe, also known as IP regimes in the EU Europe

Patent Box Regimes in Europe

Patent box regimes (also referred to as intellectual property, or IP, regimes) provide lower effective tax rates on income derived from IP. Most commonly, eligible types of IP are patents and software copyrights. Currently, 14 of the 27 EU member states have a patent box regime.

4 min read
Ways & means tax proposal seeks to combat extraterritorial taxes and discriminatory taxes Global minimum tax revenue OECD Pillar Two revenue OECD impact assessment OECD Pillar One tax Pillar one amount a Biden interest limitation Biden interest deduction rule Biden interest expense limitation Business interest expense limitation Democrat Senate international tax overhaul discussion draft legislation (Wyden Brown Warner international tax overhaul) or Sen Wyden international tax plan,

Tax Foundation Comments on the Wyden, Warner, Brown Discussion Draft

The proposed restructuring of the GILTI and FDII regimes makes several changes to the tax base that are largely offsetting, leaving virtually all the revenue potential to be determined by the tax rates on GILTI and FDII and the haircuts on foreign tax credits. Lawmakers should carefully weigh the trade-offs between higher tax revenues and competitiveness.

12 min read
Since 2017 tax reform, US corporate tax expenditures are about average in the OECD. Reuters us corporate tax in line with foreign rivals

Will FDII Stay or Will it Go?

While the Biden administration has certainly proposed to remove FDII, it is not clear that Congress is on board with that approach.

5 min read
Major changes for US companaies earning profits from Ireland Double Irish structure Irish tax haven royalty payments from Ireland Double irish structure royalty payments from ireland New Research Shows Major Changes for U.S. Companies Earning Profits from Ireland tax haven

New Research Shows Major Changes for U.S. Companies Earning Profits from Ireland

New data show that the recent policy changes that have been implemented by the U.S., Ireland, and dozens of other countries are having an impact. The question for policymakers is whether they will take the time to understand these impacts before jumping to the next project to change international tax rules yet again.

3 min read
intellectual property IP tax GILTI FDII global minimum tax Biden tax patent boxes impact business, patent boxes, software, intellectual property tax

The Balancing Act of GILTI and FDII

The tax treatment of intangible assets has come into the spotlight recently with the Biden administration proposing to undo a policy adopted in 2017 to encourage intellectual property (IP) to be located in the U.S.

6 min read
patent box regimes, European intellectual property tax, IP, patent box regimes, IP regimes, licensing

Patent Box Regimes in Europe

Patent box regimes (also referred to as intellectual property, or IP, regimes) provide lower effective tax rates on income derived from IP.

4 min read
intellectual property IP tax GILTI FDII global minimum tax Biden tax patent boxes impact business, patent boxes, software, intellectual property tax

How Patent Boxes Impact Business Decisions

As with every change in tax policy, there are trade-offs. The Modified Nexus Approach adds an additional layer of complexity to the already complex issue of taxing IP income. Linking tax breaks for IP income to its associated R&D activity has changed the game and will likely result in some businesses restructuring and relocating their IP assets and R&D activity. Effective tax rates on IP income will likely play an important role in determining optimal locations, giving measures such as R&D credits more importance. Whether this new approach to IP taxation will impact profit shifting and which countries will be the winners and losers is yet to be seen.

6 min read