«Corporate Tax Reform III»

The fifth issue of TAXeNEWS from October 4, 2013 sheds light on the UK Patent Box and its suitability for Switzerland. Since April 1, 2013, the Patent Box in the United Kingdom has benefited income from qualifying intellectual property (IP) at a reduced tax rate of 10%. The UK Patent Box offers incentives for companies that either own patents or hold exclusive licenses and have contributed to the creation of this IP through their own development activities. Qualifying rights include patents, supplementary protection certificates and certain regulatory approvals, but not trademarks. Companies working in partnerships or joint ventures can also fulfill the requirements for development activities. The criterion of active management of the IP by the company is crucial. The UK model offers advantages for companies with high margins. For Switzerland, adjustments such as an extended catalog of qualifying IP and lower routine returns could increase the attractiveness of a license box.

Topics in the publication

• Corporate Tax Reform III (CTR III)
• The UK patent box
• Comparison with other license box systems
• Suitability for Switzerland
• Conditions and requirements of the UK Patent Box
• Income categories
• Calculation of profits and tax relief
• International developments and acceptance
• Future steps and recommendations for Switzerland