Taxation of Intellectual Property

Taxation of Intellectual Property cover

Taxation of Intellectual Property

Pre-order. Available 15 Aug 2024

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This specialist title analyses the approach of the UK tax regime towards intellectual property assets. Following the life-cycle of intellectual property from creation to disposal, the commentary highlights the tax considerations and planning issues for individuals, non-corporate entities and companies. A separate chapter deals with international issues including UK tax residence, transfer pricing and controlled foreign companies.

This new edition of Taxation of Intellectual Property will be updated by Julian Hickey of Old Square Tax Chambers and Zeeshan Khilji of ETC Tax. Two new chapters are added to this edition, one dealing with crypto-assets, and the other providing guidance on dealing with disputes, enquiries and appeals, focussing on the practical issues advisors need to think about.

A large amount of new material is added to reflect changes to the law and practice in this area since the last edition was published in 2016. These include:

- changes to the corporate intangible asset regime
- expansion of guidance on the patent box to reflect application of new rules from July 2021
- changes to the R&D tax relief regime
- updated to reflect the post-Brexit world, including international protection, recognition and enforcement of UK and non-UK IP; and the new VAT regime.
- new commentary on 'hybrid' IP: domain names and protection via goodwill/passing off
- update to the international tax planning to reflect recent tax residence decisions such as Development Securities Plc v HMRC
- New case law:
- Hull City AFC (Tigers) Ltd v HMRC (image rights)
- Thaler v Comptroller General of Patent Trade Marks and Designs (confidentiality - no property in information)
- Ingenious (trading v investment
- Vaccine Research Limited (trading v investment)

The new edition will also feature a number of new examples and case studies to help illustrate the guidance given.

Table of Contents

General Introduction

Chapter 1: Introduction
Chapter 2: Introduction to intellectual property

IP tax: Individuals

Chapter 3: Creating intellectual property
Chapter 4: Research and development allowances
Chapter 5: Acquiring intellectual property – individuals and non-corporates
Chapter 6: Exploiting intellectual property
Chapter 7: Disposing of intellectual property

IP tax: Companies

Chapter 8: Corporate intangibles tax rules - introduction
Chapter 9: Creating intellectual property
Chapter 10: Research and development expenditure
Chapter 11: Acquisition of intellectual property by companies
Chapter 12: Exploitation of intellectual property by companies
Chapter 13: The patent box
Chapter 14: Disposals of intellectual property by companies

IP tax: Issues common to Individuals and Companies

Chapter 15: Value added tax
Chapter 16: International intellectual property tax issues and planning
Chapter 17: Intellectual property transactions
Chapter 18: Structures and businesses
Chapter 19: Cryptocurrencies
Chapter 20: What to do if things go wrong

Product details

Published 15 Aug 2024
Format Paperback
Edition 5th
Extent 576
ISBN 9781526524942
Imprint Bloomsbury Professional
Dimensions 234 x 156 mm
Publisher Bloomsbury Publishing

About the contributors


Julian Hickey

Julian Hickey is a barrister at Exchequer Chambers…


Zeeshan Khilji

Zeeshan Khilji is Managing Director of the Tax Con…