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Introduction

Intellectual property (IP) is increasingly being viewed as a strategic asset that is much more than a bundle of legal documents. The successful business of the future will be the one that both grasps the fact that the IP rights can be the most valuable assets in the company and succeeds in deploying those assets in the most profitable way. One of the most important factors in ensuring that IP is deployed in the most profitable/efficient way is tax. With that in mind this guide attempts to set out the main tax issues that should be considered with respect to IP. The guide is structured to mirror the IP lifecycle.
In broad terms the IP lifecycle can be broken down into 3 phases:

• Developing IP rights
• Exploiting IP rights
• Disposal of IP rights

It has been assumed for the purposes of this guide that the IP will be developed and held in a company.

• Phase 1 - Developing IP rights
• Phase 2 - Exploiting IP rights
• Phase 3 – Disposal of IP rights
• Appendix I
• Appendix II
• Appendix III
• Appendix IV
• Disclaimer