The U.K. and Germany recently issued a joint proposal on new rules for preferential IP regimes based on the modified nexus approach proposed by the OECD Forum on Harmful Tax Practices. Under this approach tax benefits are required to be directly connected with R&D expenditures. The joint proposal is intended to move negotiations forward in regard to IP regimes, and includes:
- Uplift of Qualifying Expenditure -- where related party outsourcing or acquisition costs are incurred, which do no…