Since 1 January 2007 the Netherlands offers an IP-regime, called the "Patent box", which taxes the income derived from qualifying IP at an effective tax rate of 10%. In the Dutch Budget proposals for 2010, the IP regime is broadened even further and a lower tax rate of 5% has been announced. This so-called "Innovation box" is expected to become effective per 1 January 2010.
According to Erik Bouwman, the Dutch Pharma and Life Sciences Tax leader, this new "Innovation box" regime opens up a wide area of opportunities for Pharma and Life Sciences companies.
The milestone and buy-in payments for IP, or the transfer of pipeline products that will be further developed for the account and risk of a Dutch owner are likely to qualify as well. This, combined with the opportunity to deduct all R&D expense at the full nominal rate of 25,5% makes the new regime very competitive.