BEPS that! Ireland: Here comes the New « Knowledge-Box »Par Robert Robillard - 7 novembre 2014
RBRT Inc. Transfer pricing, tax treaties and other international tax matters
Some new OECD BEPS « work » is going to be required on this one…
From the Irish Time (by A Beesley):
« Officials examine 6.25% rate for new ‘knowledge box’ scheme
Government moves to shore up investment after scrapping “Double Irish”
Irish officials are examining the feasibility of a 6.25 per cent rate on a new corporate tax scheme as the Government moves to shore up inward investment after its decision to scrap the controversial “Double Irish” mechanism.
While this is one of several options under discussion, such a rate would apply to a new “knowledge box” scheme in which a preferential rate would be levied on assets such as patents which are managed from Ireland and located here.[…]
A 6.25 per cent tax rate on intellectual property assets managed in the “knowledge box” scheme would be half the standard Irish corporate tax rate of 12.5 per cent, which itself has been a source of international controversy. »
Also at Bloomberg (by L Bershidsky):
« The first move will be to set up — as early as next year — a so-called « Knowledge Development Box. » It’s the same as the « patent box » now in place in the U.K. and the « innovation box » used by the Netherlands. These « boxes » allow companies to separate out income stemming from intellectual property and pay a different tax rate on them. In the U.K., that rate is supposed to go down to 10 percent, compared with the standard 21 percent, by 2017. In the Netherlands, it’s only 5 percent.
Irish Finance Minister Michael Noonan says the comparable Irish regime « will be best in class and at a low competitive and sustainable tax rate. » That potentially means a lower rate than the Dutch one, making it possible for tech companies to go on pretty much as before. A 3 percent tax in the « knowledge box » would be higher than the current zero rate, but it would allow companies to save by simplifying their tax structures. »
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