Category Archives: Technology

The World Intellectual Property Organization has recently suggested that one third of the value of the products that consumers buy is derived from intangibles such as technology and branding. With the growing importance and value of intangibles in mind, coupled with the government’s suggestion that technology will be one of the key drivers for the … Continue reading Budget 2018: Reform of the UK corporation tax intangibles regime

On 29 October 2018, Phillip Hammond, the Chancellor of the Exchequer, announced in his Budget that the UK will be pressing ahead with a unilateral Digital Services Tax (“DST”) from April 2020, subject to an appropriate international measure being in place. The DST will be chargeable at a rate of 2% on those revenues of … Continue reading New UK Digital Services Tax

The Finance Bill 2018-19 will introduce UK tax currently at 20% on income from intangible property held in low-tax jurisdictions to the extent that the income is referable to UK sales. This measure will come into effect from 6 April 2019. The UK tax will be levied on relevant gross income realised by non-UK resident … Continue reading UK Tax on Offshore Intangibles

Today we had the Chancellor’s first Spring Statement since the decision to move the Budget to the Autumn. The Chancellor took pains to manage expectations downwards but, while there were no major tax announcements for the new financial year, there were some interesting consultations launched and updates on earlier consultations. Entrepreneurs’ Relief (ER) ER provides … Continue reading The Spring Statement: What’s new?

The UK Government is keen to be seen as taking the lead in implementing the OECD’s recent recommendations to counteract perceived international tax avoidance. No surprise there given next year’s general election, and it is hybrid structures that are first in the firing line. In brief, hybrid structures seek to take advantages of mismatches between the … Continue reading A wrecking ball for tower structures: major reform of hybrid rules announced

The Chancellor today announced three key measures to help the UK tackle Base Erosion and Profit Shifting (“BEPS”).  The measures signal the first concrete BEPS related measures intended to be adopted into domestic legislation.  The measures are part of the UK Government’s efforts to strengthen anti-avoidance measures and in the process promote fairness in tax … Continue reading BEPS takes centre stage as Chancellor ushers in special ‘Tech Tax’

The EU VAT system is set for a significant upheaval come January 2015, potentially causing suppliers of digital products a major headache. The change aligns the rules for both EU and non-EU businesses in relation to the supply of “digital services”, so that VAT is charged on supplies to individual customers in the jurisdiction in … Continue reading Supplies of digital services by EU tech companies

The UK and German governments have agreed a joint proposal which may result in the abolition of the UK’s Patent Box regime in its current form. The main theme of the proposal is that preferential tax regimes for intellectual property (IP) should require substantial economic activities to be undertaken in the jurisdiction offering the tax … Continue reading Reform of Patent Box regime on its way

The European Council’s Expert Group on the Taxation of the Digital Economy, which was set up with the task of examining key tax issues relevant to the digital economy (“DE”), issued its final report to the EC on 28 May 2014. The main conclusions are as follows: A separate tax regime for the DE is … Continue reading Tech Sector Update: European Council issues report on the Taxation of the Digital Economy