The UK is becoming an increasingly competitive place to conduct research and/or hold intellectual property (IP). Lorna Smith, Matthew Dixon and Nicola Bellamy of Grant Thornton go through the changes to the UK tax system over a number of years, such as the extension of R&D reliefs and the introduction of the patent box regime, and their impact on transfer pricing.
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
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