Best 5 jurisdictions for receiving royalties from intellectual property rights CYPRUS The intellectual property royalty tax system in Cyprus changed as a consequence of the recommendations of the Organisation for Economic Co-operation and Development (OECD)'s Action 5 report, as well as the conclusions of the Ecofin Council, published on 8 December 2015. The legislation was amended to limit the companies that can benefit from exemptions for research and development (R&D), but the tax rate in Cyprus is still one of the most favourable in the EU for foreign companies wishing to license the use of IP to a Cyprus-resident company (intermediary), where that right is then sub-licensed to the end user. Overall, the effective tax on income from IP royalties should be less than 2.5%. IRELAND In 2015, Ireland introduced an effective corporation tax rate of 6.25% on income derived from IP, based on an allowance for the research and development costs sustained by the com...
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