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V1883-18 ·26 June 2018 ·consulta-vinculante Medium impact
Tax

Income from patent licensing may qualify for the Article 23 CIT reduction

A scientific research company has enquired whether payments for the licensing of a molecule (upfront, consolidation, and milestones) qualify for the intangible assets reduction. The DGT has ruled that patents are included in this reduction, provided all legal requirements are met.

In 6 key points

How it affects those involved

This ruling clarifies that various forms of patent licensing income are eligible for tax relief under Article 23 of the Corporate Income Tax Act, offering significant tax benefits for R&D-intensive companies.

Lifecycle

2018-06-26PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
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