Tax incentives and IP Box

We will find out which preferential regime you could actually qualify for, what the relief is tied to in each country we cover, and what it takes to keep it once you have it.

 

R&D uplift, capped

Надбавка к расходам

30% of the spend

30% от затрат

Free zone, Emirates

Фризона в Эмиратах

0%, conditions apply

0%, есть условия

When you need a preferential tax regime

Your product earns from licensing

Income comes from letting others use what you built. That is the income these regimes are written around.

You are choosing where to build

The team could sit in more than one place, and the relief differs by where the work is actually done and paid for.

You bought the technology in

The core was acquired or built by someone else. How much of the profit can reach a lower rate turns on that split.

Someone promised you a zero rate

An address in a zone was presented as the whole answer. What the rate applies to, and what must stay true, was left out.

The relief is claimed but undocumented

The lower rate is already in the return, and nobody assembled the file behind it. That file is what the claim rests on when examined.

Your regime is being reviewed

The regime you rely on is under review or has been changed. What happens to companies already in it is a separate question from what happens to new ones.

How a preferential regime is chosen

Preferential regimes come in two shapes. One lowers the tax on income from intellectual property, and how much of that income qualifies is worked out from the research the company paid for itself. The other attaches a rate to a status — a zone, a licence, a headquarters — and holds it while conditions hold.

Both shapes share two things worth knowing. Relief follows substance, so an address on its own moves nothing. And the countries running these regimes review each other’s: a regime can be amended, put under review or closed to newcomers while those already inside are given time.

What you get

  • The regimes you could qualify for
  • What each one is tied to
  • The share of profit that qualifies
  • The file behind the claim
  • What would end the relief

What the relief is tied to

  • Which assets count: a patent and copyrighted software do; a marketing asset such as a trademark can never qualify under these regimes.
  • Who paid for the development, and how much of it happened inside the company, against what was bought in or ordered from a related party.
  • Where the people and the decisions are, because a status granted on substance gets checked against it.
  • What the income is: a licence fee, a share of a sale price and a gain on disposal are treated separately.
  • What has to be kept, and for how long, so the claim can be shown years later.

Where the relief sits

Cyprus

A regime of the European kind for income from intellectual property: part of the qualifying profit leaves the base, and that share is calculated, not assumed.

United Arab Emirates

A rate attached to free zone status: 0% on qualifying income while every condition holds, and the status falls away from the first day of the period if one of them stops.

United States

A deduction for a domestic corporation on income earned from abroad. It follows where the customer is, so it can reach a company whose research sits at home.

Serbia

A regime for income from intellectual property, now under review by the group of countries assessing such regimes — worth knowing before you plan around it.

Hong Kong

A regime built to the agreed standard from the start and assessed as not harmful, so the qualifying share is calculated the same way as elsewhere.

Oman

One headline rate for companies, with a lower one for small businesses on conditions. Anything beyond that follows a status, which carries its own requirements.

Qatar

Relief attaches to zone and financial-centre status. Both were assessed as not harmful with substance requirements in place — which is what they are for.

Bahrain

What the peer review records here is a substance requirement, in force since the start of 2019, with no issues identified — and no regime of the intellectual property kind.

Saudi Arabia

Relief comes with regional headquarters status. Mandatory activities must start within six months of the licence, and at least three optional ones inside the programme’s timeframe.

Sources: relief under an intellectual property regime follows the research the company paid for itself, and where a country allows an uplift for bought-in work the agreed cap is 30% of the qualifying spend. Regimes are peer-reviewed and published. In the Emirates the rate is 0% on qualifying income, and the status is lost from the start of the period if a condition fails.

Stages of work

What the income actually is — 1 week.

We start by separating the streams: licence fees, sales carrying the technology with them, service income and everything a regime never reaches.

Regimes are written around particular kinds of income, and a company has more than one.

Who paid for the development.

We will reconstruct the spend behind the asset: what the company did itself, what it ordered from unrelated parties, what came from related ones and what was bought.

That split is what the qualifying share is calculated from, so it is assembled from invoices and contracts.

Which regimes you could actually reach.

You get the shortlist with the condition that decides each one, and a note where a regime is open on paper and closed in fact.

What the relief is worth against what it costs.

Every regime has a running cost: substance to maintain, records to keep, filings to make. Holding that substance up with you is work we take on by agreement. Both sides go into the comparison before you apply.

Applying, and building the file at the same time.

The application and the evidence are built together: the file answers the first examination, and assembling it later means reconstructing what nobody has kept.

Keeping it while the business changes.

A new hire abroad, an acquisition or a change of owner can move the qualifying share or the status itself, and rechecking the relief in later years is work we agree on.

Our tax and bookkeeping services are listed together in the Tax & Accounting area.

Our case studies

Tax Optimization via Beckham Law in Spain

Client

Private investor relocating to Spain

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Government Payroll Subsidy for Gaming Company

Client

Major international gaming company (MENA division)

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Leaders of the Area

Alexandra Kurdyumova

Alexandra

Kurdyumova

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Anton Karpenko

Anton

Karpenko

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FAQ

What is an IP Box regime?
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Can a preferential regime be taken away?
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What share of the profit actually gets the lower rate?
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