Jurisdiction(s):
United Kingdom

Related legal acts

Key definition

Acquisition definition

What does Acquisition mean? In VAT practice, an acquisition is the cross-border purchase or movement of goods between EU Member States where the goods are removed to another Member State and VAT is self-assessed in the destination by the acquirer (acquisition VAT). The term is defined in VAT legislation (UK: Value Added Tax Act 1994, as modified for Northern Ireland by the Windsor Framework/NI Protocol; Ireland: VAT Consolidation Act 2010) and also covers certain transactions treated as supplies of goods, such as a trader’s transfer of own goods across borders. Jurisdictional scope: In Ireland, intra-Community acquisitions apply in full. In the UK, the rules...

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

Published by a LexisNexis Tax expert

Practice notes

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...

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Graham Samuel-Gibbon

Taylor Wessing LLP

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....

Claire Hawley

Taylor Wessing LLP

Claire is a Senior Counsel – Knowledge in the Tax & Incentives group. She has specialised in corporate tax law since 2000, advising on the tax aspects of M&A, banking & finance, IP and real estate transactions. Claire is now responsible for all areas of knowledge management, providing technical legal support to her team and other practice areas across the firm. She has a particular focus on delivering thought leadership and keeping both internal and external clients abreast of developments in the ever-changing world of tax law. Claire has over 17 years of experience as a Knowledge Lawyer, prior to which she practised as a transactional and advisory tax lawyer at both UK and US firms....

Web page updated on 22/05/2026

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