Section 757 TCA 1997 is a specific legislative provision that imposes a charge to tax in respect of the receipt of a capital sum on the disposal of certain “patent rights”. Although it has been on the Irish statute books since 1959, s757 has come into sharper focus recently for many taxpayers and multinational groups, given the increased importance of intellectual property (IP) in current business models. Accordingly, structuring IP from an efficiency perspective is a key consideration leading to an increase in transactions involving the purchase and sale of IP (including the onshoring of IP to Ireland from abroad to align with existing substance of Irish operations).
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