Global

Details

  • Service: Tax, Global Indirect Tax, Global Compliance Management Services, International Tax
  • Type: Regulatory update
  • Date: 5/3/2013

United Kingdom - 90-day patent; interest subject to tonnage tax 

May 3: The UK Intellectual Property Office in April 2013 issued a consultation document requesting comments on its proposed "90-day patent."

A late December 2012 announcement from the Intellectual Property Office revealed that it would introduce a 90-day patent in 2013. Under the new 90-day patent process, in return for a premium processing fee (approximately £3,500-£4,000), the Intellectual Property Office would endeavour to complete the patenting process within 90 days from application to grant. See TaxNewsFlash-Europe: United Kingdom - Proposed “90-day patent” and patent box regime


The Consultation document anticipates legislative changes “at the first available opportunity” (once details of the new process are completed), but does not commit to a definite timetable. Comments are requested by 12 June 2013.

Interest may be subject to tonnage tax

The First Tier Tribunal decided that interest income arising from deposits (cash collateral) required as part of financing arrangements for the acquisition of vessels may be subject to the tonnage tax regime. Euroceanica (UK) Ltd. v. HM Revenue and Customs; TC/2012/03605 (4-6 March 2013)


Read the decision: Euroceanica [PDF 298 KB]

KPMG observation

UK tonnage tax groups need to review whether they have reported such interest outside the tonnage tax regime, and whether they need to amend previously submitted tax returns to reflect the decision. Tax professionals have observed that with this decision, not all investment income will fall within the tonnage tax regime—only income from deposits required to be made (for example) in connection with the acquisition of ships is likely to be accepted as exempt.


Other topics covered in the KPMG report include:


  • Single compliance process trial for SMEs - update
  • Investment trust companies - draft regulations
  • Community investment tax relief - guidance
  • Tax Journal - International Briefing for April
  • Changes to short term business visitors agreement
  • Sleeping and inactive partners - NIC liability
  • Reform of transfer of assets abroad legislation
  • VAT - Remaining VAT grouping infringement cases



©2014 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ("KPMG International"), a Swiss entity. All rights reserved.


The KPMG logo and name are trademarks of KPMG International.


KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever.


The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.


Direct comments, including requests for subscriptions, to us-kpmgwnt@kpmg.com.
For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at:

+ 1 202 533 4366

1801 K Street NW
Washington, DC 20006.

 

Share this

Share this

Subscribe

Subscribe to receive the latest TaxNewsFlash email alerts (you must select the option for TaxNewsFlash)


Already a Subscriber? Login


Not a member? Subscribe now