A UK company acquired a portfolio of out-of-patent pharmaceutical assets from a related partnership under the UK intangibles regime. HMRC challenged the £40 million market value, arguing assets were worth approximately £9 million with a longer amortisation period. The First-Tier Tribunal allowed Chemidex's appeal in 2024, upholding the income-based valuation and rejecting HMRC's approach to both value and useful economic life ... Read more

A Luxembourg company treated itself as the economic owner of trademarks licensed from a US related party under a 25-year agreement and claimed the Luxembourg IP exemption regime. The tax authorities denied the exemption, finding no transfer of economic ownership. The Administrative Court upheld this position in 2024, ruling that the licence agreement clearly identified the US licensor as sole owner and that legal form and economic reality aligned ... Read more