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Qualifying IP
IP box
rate
(%)
CIT
rate
(%)
Type of eligible IP
Exi
sti
ng
IP
Treatment
of current
expenses
Treatment of
R&D expenses
incurred in the
past
Belgium (2007)
6.8
33.99
Gross
income
No recapture
Cyprus (2011)
10
Net income
No recapture
France (2000)
15.5
34.43
Net income
No recapture
Hungary (2003)
9.5
19
Gross
income
No recapture
Liechtenstein
(2011)
2.5
12.5
Net income
Recapture
Luxembourg
(2008)
5.84
29.22
N* Y*
Net income
Recapture
(Capitalisation of
development
costs)
Malta (2010)
35
Not
applicable
Income not
eligible if R&D
costs previously
deducted
Netherlands
(2007)
25
Net income
Recapture
Spain (2008)
12
30
Net income
No recapture
Nidwalden,
Switzerland (2011)
8.8
12.66
Net income
No recapture
United Kingdom
(2013)
10
23
Y*
Net income
before
interest
Italy (2015)
13.75
27.5
Net income
+
recapture seems
to be included (to
be clarified)+
or SPCs
Abbreviations: CIT: corporate income tax rate, including surcharges; Y: Yes; N: No; SPC: Supplementary Protection Certificate.
Notes: (*) Luxembourg and the UK allow acquired IP only under certain conditions. In the first column the data refers to the year in
which an IP Box was first introduced. In Luxembourg, IP created before the introduction of the regime qualifies if it has been
acquired after the date of the implementation. For France the corporate tax rate includes the social surcharge, but not the
exceptional tax surcharge that is levied if company turnover exceeds EUR 250 Million. The UK regime is being phased in over four
years. In 2013, companies are only entitled to 60% of the full benefit, increasing to 70%, 80% and 90% in subsequent years and
becoming fully available in 2017.
(+) The IT IP regime - a 5 years option (renewable for another 5) - is built as an exclusion from the tax base of the income derived
from the IP (with a ratio which reflects the proportion between R&D costs and total costs to produce the IP asset). Costs for
acquired Intra-group IP contribute to the ratio of the IP BOX eligible income only for 30% of the total. The IT regime is being
phased in over three years. In 2015, companies are only entitled to 30% exclusion from the tax base, increasing to 40% and 50%
in subsequent years and becoming fully available in 2017. Some of the aspects still need to be defined or clarified.