1.
Rebekah Davis
Accounting Theory
Dr. Roger Daniels
December 11, 2015
Thinking Outside the Box: Taxing the Patent Box
Background:
Globalization of the economy has introduced new challenges and complexities
within the realm of tax policy and tax political realities. U.S. multinational companies
have successfully lowered their overall tax liability for decades as a percentage of total
U.S. revenue. In fact, U.S. corporations make up only 11 percent of total U.S. tax
revenue.1
Companies are utilizing the lack of geographical location and mobility of
intangible property to locate it in tax advantageous locations or “tax havens.” A tax
haven can be defined under D.C. Code §1801.04(49) as “a jurisdiction that satisfies one
of several qualitative requirements (e.g., a jurisdiction that has a nominal effective tax
rate, that lacks transparency, that has a tax regime favourable for tax avoidance).2”
Several European countries have implemented “patent boxes” to attract
intangible property from multinational corporations. A patent box is a special tax regime
for intellectual property revenues that allows income from intangible property to be taxed
at a lower rate, decreasing overall tax liability. Patent boxes are focused on the sale and
commercialization of existing IP assets. In order to keep intangible property and jobs
within the U.S., Congress has discussed the possibility of adopting legislation to create a
patent box within the United States.3
The legislation has met many critics.
The purpose of this paper is to discuss the theoretical constructs of the patent
box. The implications of the adoption of the patent box in the United States are
considered in reference to implementation cost and impact on tax revenue. The Joint

2. 2
Committee on Taxation has estimated that broader changes to foreign income taxation
would raise $115 billion in federal revenue within a 10 year window used for evaluating
the impact of tax legislation.4
Estimates provided by the Joint Committee on Taxation are
discussed later. The international influence of the Organisation for Economic
Cooperation and Development is explored in reference to the recent Base Erosion and
Profit Shifting (BEPS) project. In addition, current and proposed U.S. patent legislation is
discussed. The arguments for and against the U.S. patent box are presented. The paper
concludes with the socioeconomic effects of the U.S. patent box in reference to global
tax and economic systems and ethical implications. Finally, the impact on the current
CPA is discussed in regards to awareness, client service and forecasting.
Introduction:
The complexity of the U.S. tax code has led to discussions concerning tax
reform. Domestic economic growth and global competitiveness are at the forefront of
these discussions. The United States has the world’s highest statutory corporate tax rate
and the second-highest effective tax rate.5
In addition, U.S. multinational corporations
are taxed on their worldwide income rather than income derived from their own
jurisdictions, therefore increasing their overall tax liability.5
In reality, however, very few
corporations pay the effective tax rate of 35 percent.
Due to the relatively high U.S. corporate tax rate and the complexity associated
with the foreign tax credit, U.S. multinational corporations are taxed at a higher rate on
foreign income than on domestic income. 6
As a result, active foreign earnings are
generally not repatriated. 7
In contrast, earnings are typically reinvested to support U.S.
foreign operations in emerging markets. Accumulated foreign earnings held overseas
are estimated to exceed $2 trillion.8
Earnings from intellectual property account for the
majority of the $2 trillion held overseas.7
In addition to unrepatriated earnings,

3. 3
inversions, mergers and acquisitions and other methods of tax home transfers are
becoming increasingly popular.5
Intangible assets are valuable to companies due to their mobility and worth
across international borders. Empirical studies have shown that the location of intangible
assets is receptive to corporate income tax. 6
Consequently, countries are enacting
patent box regimes and other foreign based strategies to lower corporate income taxes
on intangible property to attract domestic investment. The patent box method is the
focus of this article.
What are Patent Boxes?
Intangible property does not have a physical or geographical existence. Instead,
intangible property is a creation of the mind. As a result, corporations have great
flexibility and incentive to move intellectual property to low-tax jurisdictions to reduce
their overall tax liability.9
Patent boxes, so called because taxpayers must elect the
benefits of a patent box by checking a box on their tax return, are creating tax incentives
to move intangible property by providing lower tax rates on the income from the sale or
commercialization of intangible property.10
The name “patent box” can be misleading. Different types of intangible property
are permissible under a patent box, including patents, trademarks and copyrights.9
The
intangible property is “boxed” off and the profits from commercialization are taxed at a
preferential rate.9
Often called “innovation boxes” or “IP boxes”, patent boxes should be
distinguished from research and development (R&D) tax credits. R&D credits offer
benefits at the front-end of production by providing incentives to perform research and
development activities. In contrast, patent boxes provide benefits after research and
development activities have been performed and intangible property has been
established.

4. 4
Several countries have already implemented patent box legislation, including
China, Italy and the U.K. However, patent boxes look differently depending upon the
specific country’s application and legislation. Differences can be attributed to the
following: the eligibility of certain kinds of intangible property, the definition of qualifying
income and the method in which research and development expenses are treated.7
Patent boxes are applied using either a reduced tax rate on qualifying income or a
certain exemption of income from intangible property.7
These methods impact financial
reporting differently. For example, if revenues from intangible property are partially
exempt, an increase in loss carry-forwards could result, enabling the company to benefit
in subsequent periods. Conversely, if specific exclusion rates are applied to intangible
property income, there will be no effect on loss carry-forwards.7
The effect on financial
reporting should be considered by individual countries considering a patent box regime.
Some countries do not limit patent boxes to domestically developed or acquired
intangible property.7
In this situation, patent box regimes are not supporting domestic
research and development in intellectual property. Instead, countries are competing for
domestic placement of previously developed intangible property. This situation can be
detrimental to the global economy. The impact on the global economy will be discussed
later in this paper.
In order to avoid unhealthy competition, some countries are focusing on the
economic substance of intangible property. Ultimately, the goal of a patent box is to
encourage domestic production while maintaining international competitiveness in an era
of global technological innovation. If countries focus on the economic substance of
intangible property, multinational corporations will focus more on keeping their intangible
property within the domestic country without the harmful repercussions of unhealthy

5. 5
competition, which ultimately causes a negative ripple effect throughout the global
economy.
OECD BEPS Project:
The issues inherent in patent boxes deal with tax avoidance strategies. Tax
avoidance and tax evasion are not the same thing. The IRS defines tax avoidance as
“an action taken to lessen tax liability and maximize after-tax income.” In contrast, tax
evasion is “the failure to pay or a deliberate underpayment of taxes.” 11
However, the line
between tax avoidance and tax evasion is often hard to determine.
Questions concerning the effectiveness of patent boxes have been raised in light
of recent tax avoidance strategies. Do patent boxes support domestically performed
research and development? Or do they provide a way for a country to “underbid its
neighbor, entice IP migration, and earn tax revenue from activities that are never, in a
practical sense, really there.”12
The Organization for Economic Cooperation and
Development (OECD) has started a base erosion and profit shifting (BEPS) project to
address these concerns and other “harmful tax practices.” Base erosion and profit
shifting (BEPS) includes “tax planning strategies that exploit gaps and mismatches in tax
rules to make profits ‘disappear’ for tax purposes or to shift profits to locations where
there is little or no real activity but the taxes are low, resulting in little or no overall
corporate tax being paid.”12
BEPS occurs when corporate taxes interact with domestic tax systems.
Oftentimes, the differences inherent in domestic tax systems can be arranged to achieve
double non-taxation. The arrangements are usually legal but often interfere with fair
competition. The OECD BEPS Project addresses the issues of double non-taxation by
achieving “the alignment of profit and operational substance.” 13

6. 6
BEPS has had a significant impact on global taxation with estimates ranging from
4 to 10 percent of global corporate income tax (CIT) revenues. Using a very
conservative estimate, the USD equivalent is anywhere from $100 to $240 billion of
annual lost revenue.14
The OECD BEPS Project does not address the tax avoidance
strategies or abuses of the global tax system. Instead, the project focuses on fixing the
problems within the global tax system that enable these strategies or abuses to happen.
The BEPS problem is a universal concern that requires universal solutions.
These solutions are often found in amending bilateral tax treaties. The OECD BEPS
Project outlines 15 objectives to address within the international tax rules by the end of
2015.12
One of the key objectives of the BEPS Project is to implement a multilateral
instrument that will enable bilateral tax treaties to be updated in one step, ensuring
effectiveness and efficiency.15
Ultimately, the main purpose of the BEPS Project is “to
help governments protect their tax bases and offer increased certainty and predictability
to taxpayers, while guarding against new domestic rules that result in double taxation,
unwarranted compliance burdens or restrictions to legitimate cross-border activity.” 15
The OECD BEPS Project addresses patent box regimes through the modified
nexus approach. The modified nexus approach is a key element of Action 5 of the BEPS
Action Plan.16
The “nexus principle” is designed to allow benefits from patent box
regimes only when businesses perform “substantial activities” in the country where the
intellectual property income is being generated. The approach measures “substantial
activity” through research and development expenditures.17
The reduced corporate tax
rate benefit would be calculated using the “nexus fraction.” The fraction’s numerator
would include any R&D expenditures the taxpayer invested in intangible property plus
any outsourced R&D to an unrelated party, termed “qualifying expenditures.” The
fraction’s denominator would include the qualifying expenditures plus outsourced R&D to

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a related party, termed “non-qualifying expenditures.” The income derived from
intangible property would be multiplied by the nexus fraction to determine the amount of
income that would be taxed at the preferential rate under the patent box regime.17
As stated above, keeping track of research and development expenditures is not
that simple. Companies may have to incur additional costs to keep detailed records of
their R&D activities. Even if the benefits outweigh the costs, certain businesses may not
be able to easily trace their R&D activities due to outsourcing or complex business
environments. The OECD said the following in regards to their recent BEPS project:
In an increasingly interconnected world, national tax laws have not always kept
pace with global corporations, fluid movement of capital, and the rise of the
digital economy, leaving gaps and mismatches that can be exploited to generate
double non-taxation. This undermines the fairness and integrity of tax systems.14
The OECD BEPS Project is working hard to implement international tax reform
that addresses several issues, including the taxation of intangible property. The ultimate
goal is convergence of national practices to end double non-taxation. It is important to
highlight that the recommendations provided by the OECD have no legal authority and
are simply recommendations. However, the recommendations provided by the OECD
are an important source of global influence and should not be disregarded. Congress
should carefully consider the recommendations provided by the OECD BEPS Project as
the United States considers the implementation of patent box legislation.
U.S. Patent Legislation:
The U.S. federal tax code already has a provision that allows for the subsidy of
research and development expenditures through the R&D credit under IRC Section 41.18
However, current law does not offer a provision for IP income derived from the research
and development investment in intangible property.3
Even though the R&D credit should
theoretically flow through to provide a lower rate on intangible property after its

8. 8
development, Congress is discussing the possibility of implementing a patent box
regime.
The motivation behind a U.S. patent box would be “to reduce the cost and risk of
innovating and to put American companies operating domestically in a stronger position
to compete with innovators overseas in jurisdictions that have both lowered their
corporate rates and enacted incentives to innovate.”10
The recent OECD BEPS Project
has led to concerns that U.S. multinational corporations will start moving more of their
research and development activities and related jobs overseas in order to meet the
“substantial activity” recommendation provided by the OECD.19
In response, the Ways and Means Committee, led by chairman Paul Ryan,
released a discussion draft and technical explanation of a proposed patent box regime.
The proposed legislation referred to as the “Innovation Promotion Act of 2015” was
introduced by Representatives Charles Boustany (R-LA) and Richard Neal (D-MA) and
has met bipartisan support.3
The discussion draft outlines a 71 percent deduction for
income from intangible property. The proposal provides a definition of qualified income
that includes licensing fees and product sales related to patents.18
However, not all of the
qualified income is eligible for the deduction. The eligibility for the deduction would be
determined using a formula, which “multiplies ‘tentative innovation profit’ by a fraction,
the numerator which is five years of domestic R&D and the denominator of which is five
years of ‘total costs’.”20
The numerator is defined in reference to Section 174 of the tax
code which refers to domestic R&D.20
The denominator includes total global costs minus
cost of goods sold, interest and taxes.20
The result is the amount of IP income that will
receive a 71 percent deduction, resulting in an effective tax rate of around 10 percent.20
The Ways and Means Committee provides the following example:
[A] company may receive $500 of revenue from the sale of a newly invented
toaster. The total costs associated with those sales are $400, leaving the

9. 9
company with a $100 profit. Of those $400 of costs, 50 percent or $200 were
qualifying research and development costs. The patent box would require that a
company multiply its $100 of profits attributed to the new toaster by 50 percent
(the share of research and development costs to total costs attributed to the
toaster). This means that only 50 percent, or $50 would receive the 71 percent
deduction and face a 10.15 percent tax rate. The remaining income would be
treated as ordinary income and be taxed at 35 percent.18
There has been a recent push to implement a U.S. patent box for several key
reasons. First, most tax experts believe that the U.S. tax code is outdated and
uncompetitive. The U.S. has a 35 percent corporate income tax rate, which increases to
39 percent when considering state and local income taxes. The U.S. not only has the
highest rate compared to other developed countries, but it stands in stark contrast to the
25 percent average rate of other developed countries. Second, the high U.S. corporate
tax rate is causing corporations to move their business and intangible property overseas.
The reasoning behind a U.S. patent box would be to bring some of that activity home,
hopefully generating additional U.S. tax revenue.18
The third reason for the U.S. patent box is the OECD BEPS Project. Under the
project, U.S. multinational companies may have to move their R&D activities to foreign
countries to satisfy the “substantial activity” requirement to reap the benefits of patent
boxes overseas. Congress is concerned that the new requirement will encourage U.S.
multinational corporations to move their tax homes overseas. Finally, the implementation
of a patent box regime in the U.S. would hopefully encourage R&D activities and jobs
within the U.S. by offering a lower rate on the income derived from intangible property.18
The advantages of the U.S. patent box have been discussed, but there are
several concerns that must be addressed. First, critics of the U.S. patent box are afraid
that the provision will end up like the Section 199 manufacturing deduction passed by
Congress and added to the IRC in 2004. At first, the definition of manufacturing income
was narrowly defined. As time passed, this definition was expanded to include more

10. 10
qualified income. The result was a definition that was beyond recognition. Critics are
concerned that the patent box will result in an increasingly broadened definition of
qualified income, as corporations push for greater tax breaks. If this occurs, the
effectiveness of the patent box will be undermined since the lower rate will no longer
apply to purely IP income.18
Another issue that must be addressed is the implementation cost of the U.S.
patent box. The Joint Committee on Taxation has not been able to provide a cost
estimate for the patent box legislation.21
The JCT projected that broader changes to
foreign income taxation would raise $115 billion in federal revenue within a 10 year
window used for evaluating the impact of tax legislation.4
However, the JCT projection
cannot be applied specifically to the patent box legislation as it assesses broader tax
reform. As KMPG observed, “The innovation box proposal is not accompanied by an
estimate of the revenue cost, which could be substantial, nor does it offer any indication
of whether or how the revenue cost might be offset.”22
The short-term effect of the patent box regime cannot be assessed due to the
lack of Congressional cost and revenue estimation. However, it is probable that the long-
term effect of the patent box regime would be a decrease in federal income tax revenue
due to the lower tax associated with the repatriation of foreign earnings that otherwise
would have been taxed at a higher rate. Key leaders of the House Ways and Means
Committee have also hinted that the patent box may halt other tax reform objectives,
such as the reduction of the U.S. corporate tax rate. The long-term revenue effects could
increase as companies push to include other forms of revenue in the “qualified” income
definition.4
Another issue that should be highlighted is political discussions concerning a
potential tax holiday. U.S. GAAP and IFRS do not provide a definition for a tax holiday.

11. 11
However, the FASB does provide guidance on how to account for a tax holiday.23
A tax
holiday is a government incentive program that provides a reduced tax rate to
businesses to boost the economy or meet certain objectives. Congress passed the last
repatriation tax holiday in 2004 under President George W. Bush. Companies were able
to bring foreign earnings back to the U.S. at a tax rate of 5 percent instead of the usual
35 percent tax rate.24
Despite the holiday being part of an economy stimulus plan,
evidence supports that the tax holiday did little to stimulate the economy.
Democrat Barbara Boxer of California and Republican Rand Paul of Kentucky
have recently proposed another tax holiday allowing businesses to pay only 6.5 percent
corporate income tax on the repatriation of foreign earnings.14
Under the U.S. tax
system, active foreign earnings are not taxable until they are repatriated to the U.S. The
tax holiday would aim at taxing offshore profits, which are estimated to be $2.1 trillion.14
Tax experts are critical of the holiday due to its costs. The proposal would most likely
raise short-term tax revenue but would harm long-term U.S. tax reform. Ultimately, the
tax holiday would encourage companies to keep active foreign earnings abroad until the
next tax holiday. The U.S. patent box is another method used to encourage U.S.
multinational corporations to repatriate their active foreign income to the U.S.
Oftentimes, the companies that benefit the most from Congressional stimulus
projects are not doing their part. Critics of the patent box argue that the patent box may
be rewarding companies that continue to take advantage of the tax system to avoid
paying their fair share of taxes. Some argue that this is just another case of corporate
welfare – granting benefits to corporations in exchange for nothing.25
The biggest
concern with the patent box regime is that it will result in another tax provision that U.S.
multinationals can manipulate to lower their overall tax liability while relying on others to
pay higher taxes or cut program budgets.4

12. 12
As previously shown, the proposed “Innovation Promotion Act of 2015” has met
increased controversy. Several questions and concerns must be addressed in evaluating
the effectiveness of a U.S. patent box regime. Whether a patent box regime is
implemented in the U.S. or not, it is clear that Congress must do something to reform the
U.S. tax code. The U.S. Government Accountability Office (GAO) said the following
concerning tax reform:
To the extent that a tax system is not simple and efficient, it imposes costs on
taxpayers beyond the payments they make to the U.S. Treasury. Further, the tax
system’s integrity and fairness is threatened if honest taxpayers believe that
significant numbers of individuals and businesses are not paying their fair share
of taxes.26
GAO’s statement highlights the potential impact of the U.S. patent box. It is not just
another stimulus plan or tax provision. In fact, the implications go far beyond the global
tax system.
Socioeconomic Effects of the U.S. Patent Box
In addition to the implementation cost and revenue concerns associated with the
U.S. patent box, there are two socioeconomic effects that should be discussed. The U.S.
patent box impacts the international socioeconomic environment both globally and
ethically. The global and ethical constructs of the U.S. patent box should be considered
before any Congressional action is taken to implement the U.S. patent box.
The global impact of the U.S. patent box should not be taken lightly. If the patent
box is not designed property, it could foster unhealthy competition for domestic
placement of previously developed research and development. The result could
ultimately lead to the deterioration of the global tax system. This situation is especially
concerning for third world countries due to their dependency on federal income tax
revenue. These countries simply cannot afford to sacrifice short-term federal income tax
revenue to achieve long-term benefits, especially when the long-term benefits are not

13. 13
guaranteed. The inability to provide lower corporate tax rates and incentives for
intangible property could ultimately lead to the further deterioration of the domestic
economies of third world countries.
The ethical implications of the U.S. patent box raise several concerns. The
majority of the general public believes that U.S. multinational corporations are not paying
their fair share of federal income taxes. This belief raises the question – should we give
a break to companies that already take advantage of the tax code, only to shift the tax
revenue responsibility to corporations that have been paying their fair share all along?
As previously mentioned, federal corporate income tax comprises a mere 11 percent of
total U.S. tax revenue.1
In fact, federal corporate income tax collections are near historic
lows as a share of the U.S. economy.
The U.S. patent box would determine decisions made by politicians, corporations
and individuals. An important ethical concern of the U.S. patent box is the potential for
manipulation through the legislative process and the definition of “qualified” income.
Congress may feel the pressure to expand the definition of “qualified” income used to
calculate the tax benefit of the patent box. The Section 199 deduction provides historical
evidence that Congress has felt pressure from U.S. multinational corporations to expand
definitions before. At first, the definition of “qualified” income under Section 199 was
defined narrowly. However, as time went on, the definition expanded to one that
included more than income derived from manufacturing activities.
In addition, corporate tax departments may undermine the tax system by
reclassifying as much income as possible to meet the “qualified” definition. Ultimately,
the goal of corporations is to increase shareholder value and meet or beat market
expectations. Corporations will use any provision available to them to lower their overall
tax liability to increase their profits. However, these provisions are not always applied

14. 14
ethically, due to the tendency of corporations to push the limit in order to achieve greater
tax savings.
Corporate decisions ultimately affect individual investment decisions.
Corporations that are successfully reducing their tax liability and therefore, increasing
their profits may look more appealing to investors. If a U.S. patent box is not
implemented, U.S. investors may become more likely to invest in U.S. multinational
corporations that are moving their operations oversees to lower overall tax liability, which
could lead to a decrease in investment in U.S. multinational corporations based here in
the U.S. The socioeconomic effects of the U.S. patent box are an important
consideration in U.S. patent box legislation. They are also an important consideration for
the current CPA.
Implications for the Current CPA:
The current CPA should be aware of the proposed U.S. patent box and how it
may affect their clients. CPAs may already be aware of foreign patent boxes as clients
shift their intangible property abroad. As previously mentioned, the U.S. patent box
calculates its tax benefit based on research and development expenditures. This may
lead to concerns for CPAs due to the difficulty in tracking R&D expenses. Due to R&D
outsourcing or complex business environments, tracking R&D may be extremely difficult
and could even be impossible. In addition, the cost of tracking R&D may not be worth
the benefit derived under the patent box provision.
Ultimately, if CPAs are aware of the U.S. patent box provision, they will be better
equipped to engage in adequate tax planning with their clients. For example, CPAs will
be able to better advise their client on where to place their intangible property. However,
CPAs have to be careful. The line between tax avoidance and tax evasion is often hard
to tell and can lead to serious repercussions. CPAs should be aware of other foreign tax

15. 15
strategies such as mergers and acquisitions and inversions that help their clients.
Ultimately, CPAs must understand the balance between helping their client and being
ethical.
Conclusion:
Patent boxes continue to have a significant impact on the behavior of U.S.
multinational corporations. The Congressional Ways and Means Committee has
released draft legislation that would implement a U.S. patent box in the U.S. The
theoretical constructs of the U.S. patent box have been discussed in reference to
implementation cost and impact on tax revenue. In addition, the socioeconomic
concerns of the U.S. patent box have been highlighted. Ultimately, CPAs should
understand that the U.S. patent box is not just another tax provision but that the
provision impacts the behavior of politicians, corporations and individuals. Whether
Congress implements a patent box in the U.S. or not, it is clear that tax reform within the
U.S. tax code is inevitable. Current CPAs should be aware of the global landscape in
which patent boxes play a role and should anticipate future changes to the U.S. tax code
to better serve their clients.

16. 16
Works Cited
1 Office of Management and Budget. 2015. 11 November 2015
<https://www.whitehouse.gov/omb/budget/Supplemental>.
2 PwC. Tax Insights from State and Local Tax Services. 31 August 2015. 23
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insights/dc-market-based-sourcing-tax-haven-expansion.html>.
3 Boustany, Rep. Charles and Rep. Richard Neal. Committee on Ways and Means .
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content/uploads/2015/07/Boustany-Neal-IP-box-section-by-section-FINAL.pdf>.
4 Thorton, Alexandra. Patent Box Dodge: Why the Patent Box Does Not Answer
America's Need for Tax Reform. 1 June 2015. 9 November 2015
<https://www.americanprogress.org/issues/economy/news/2015/06/01/114088/paten
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regime-201513302.html>.
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emerges-us-tax-reform/>.
11 The Internal Revenue Service. The Difference Between Tax Avoidance and Tax
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<https://apps.irs.gov/app/understandingTaxes/whys/thm01/les03/media/ws_ans_thm
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17. 17
12 The Organisation for Economic Cooperation and Development. Top 10 FAQs about
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frequentlyaskedquestions.htm>.
13 Gregory, Adrian. BEPS and IP - it's all about substance. 2015 November 2015. 1
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substance.html>.
14 The Organisation for Economic Cooperation and Development. About Base Erosion
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about.htm>.
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implementation-of-oecd-g20-efforts-against-tax-avoidance-by-multinationals.htm>.
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<http://www.oecd.org/ctp/explanatory-paper-beps-action-5-agreement-on-modified-
nexus-approach-for-ip-regimes.pdf>.
17 Out-Law. UK to modify Patent Box in line with OECD recommendations. 20
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recommendations/>.
18 Pomerleau, Kyle. Ways and Means Committee Introduces 'Innovation Box'
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and-means-committee-introduces-innovation-box-discussion-draft>.
19 McKinnon, John D. Lawmakers Unveil Tax Plan on Intellectual Property . 29 July
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plan-on-intellectual-property-1438195972>.
20 Morrison, Philip Esq. Patent Boxes and the Location and Amount of Income from
Intangibles. 7 October 2015. 11 October 2015 <http://www.bna.com/patent-boxes-
location-n57982059189/>.
21 Gardner, Matt. Innovation Boxes and Patent Boxes: Congress Is Focusing on
Corporate Tax Giveaways, Not Corporate Tax Reform. 31 July 2015. 21 October
2015
<http://www.taxjusticeblog.org/archive/2015/07/innovation_boxes_and_patent_bo.ph
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