Graham Samuel-Gibbon
Graham is Head of the UK Tax and Incentives team at Taylor Wessing. He is an international tax specialist who advises domestic and multinational clients on a wide range of transactional and advisory tax matters. Graham regularly works with FTSE 100 and Future Global 100 companies.
He guides clients through stock and asset/business acquisitions and disposals, cross border tax structuring, UK inbound and outbound investment, joint ventures and reorganisations.
He also advises on tax issues relating to the development, ownership and exploitation of intellectual property rights, with a particular focus on the life science and technology sectors.
Practice Area
Panel
- Contributing Author
Qualified Year
- 2005
Experience
- EY (2014 - 2017)
- Latham & Watkins (2007 - 2014)
- Hogan Lovells (2005 - 2007)
Qualification
- MA (Law with French Law) (2001)
Education
- University of Oxford (1997-2001)
- Paris-Pantheon-Assas University (1999-2000)
2 Contributions by Graham Samuel-Gibbon
PRACTICE NOTES
UK tax structuring for cross‑border IP development and acquisition: IFA regime, merged RDEC/ERIS, overseas R&D restrictions, transfer pricing, trading requirement, capital allowances, and patent box nexus
Successive UK governments have aimed to cement the UK as one of the world’s most appealing settings for innovation and enterprise. To that end, a wide-ranging suite of tax incentives has been rolled out to encourage innovative companies, supporting both investors and trading entities, and assisting businesses at every phase of a business’s life cycle. These incentives include:
R&D tax reliefs
patent box
business asset disposal relief (previously entrepreneurs’ relief)
capital allowances for purchases of:
knowhow
patents, and
plant and machinery
venture capital trusts
the enterprise investment scheme, and
the seed enterprise investment scheme
This Practice Note outlines the UK position on key tax considerations when determining how to structure an innovative business with international or global aspirations. The observations are general in nature and work on the basis of a clean slate; revisiting an existing IP ownership arrangement will inevitably demand a bespoke solution (notably for joint ventures or consortia), though the same underlying matters will still be likely to warrant careful attention. The emphasis here is on businesses creating and/or planning to acquire IP. See also Practice Note: UK tax aspects of cross-border IP structuring—exploitation...
Tax
PRACTICE NOTES
UK taxation of cross-border IP exploitation: patent box, withholding taxes and DTTs, profit extraction, CFC/UTPR risks, VAT
This Practice Note
The UK government has long aimed to make the country one of the world’s most appealing places for innovation and enterprise. To achieve this, it has introduced a range of tax incentives that support innovative companies and their investors, spanning every stage of a business’s life cycle. These include:
R&D tax reliefs
the patent box
business asset disposal relief (formerly entrepreneurs’ relief)
amortisation deductions for companies acquiring intellectual property
capital allowances for purchases of:
knowhow
patents
plant and machinery
venture capital trusts
enterprise investment scheme
seed enterprise investment scheme
This Practice Note outlines the UK perspective on key tax considerations when deciding how to structure an innovative IP business with international or global ambitions. The comments are high level and assume a blank slate; revising an existing IP ownership model will need a bespoke plan (particularly for joint ventures or consortia), though the points below will still merit attention. The emphasis is on businesses that exploit IP. Please also see Practice...
Tax
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