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This excerpt taken from the ELN 6-K filed Mar 30, 2009. Taxation
of Corporate Income
We are a public limited company incorporated and resident for
tax purposes in Ireland. Under current Irish legislation, a
company is regarded as resident for tax purposes in Ireland if
it is centrally managed and controlled in Ireland, or, in
certain circumstances, if it is incorporated in Ireland. The
Taxes Consolidation Act, 1997 provides that a company that is
resident in Ireland and is not resident elsewhere shall be
entitled to have certain income from a qualifying patent
disregarded for tax purposes. The legislation does not provide a
termination date for this relief, although with effect from
1 January 2008, the amount of this income that is
disregarded for tax purposes was capped at €5 million
per year per group. A qualifying patent means a patent in
relation to which the research, planning, processing,
experimenting, testing, devising, designing, developing or
similar activities leading to the invention that is the subject
of the patent were carried out in an European Economic Area
state. Income from a qualifying patent means any royalty or
other sum paid in respect of the use of the invention to which
the qualifying patent relates, including any sum paid for the
grant of a licence to exercise rights under such patent, where
that royalty or other sum is paid, for the purpose of activities
that would be regarded under Irish law as the manufacture of
goods (to the extent that the payment does not exceed an
arms-length rate), or by a person who is not connected with us.
Accordingly, our income from such qualifying patents is
disregarded for tax purposes in Ireland. Any Irish manufacturing
income of Elan and its subsidiaries is taxable at the rate of
10% in Ireland until 31 December 2010. Any trading income
that does not qualify for the patent exemption or the 10% rate
of tax is taxable at the Irish corporation tax rate of 12.5% in
respect of trading income for the years 2003 and thereafter.
Non-trading income is taxable at 25%.
Table of Contents
Shareholders’
Information
This excerpt taken from the ELN 20-F filed Feb 26, 2009. Taxation
of Corporate Income
We are a public limited company incorporated and resident for
tax purposes in Ireland. Under current Irish legislation, a
company is regarded as resident for tax purposes in Ireland if
it is centrally managed and controlled in Ireland, or, in
certain circumstances, if it is incorporated in Ireland. The
Taxes Consolidation Act, 1997 provides that a company that is
resident in Ireland and is not resident elsewhere shall be
entitled to have certain income from a qualifying patent
disregarded for tax purposes. The legislation does not provide a
termination date for this relief, although with effect from
January 1, 2008, the amount of this income that is
disregarded for tax purposes is capped at €5 million
per year per group. A qualifying patent means a patent in
relation to which the research, planning, processing,
experimenting, testing, devising, designing, developing or
similar activities leading to the invention that is the subject
of the patent were carried out in an European Economic Area
state. Income from a qualifying patent means any royalty or
other sum paid in respect of the use of the invention to which
the qualifying patent relates, including any sum paid for the
grant of a license to exercise rights under such patent, where
that royalty or other sum is paid, for the purpose of activities
that would be regarded under Irish law as the manufacture of
goods (to the extent that the payment does not exceed an
arms-length rate), or by a person who is not connected with us.
Accordingly, our income from such qualifying patents is
disregarded for tax purposes in Ireland. Any Irish manufacturing
income of Elan and its subsidiaries is taxable at the rate of
10% in Ireland until December 31, 2010. Any trading income
that does not qualify for the patent exemption or the 10% rate
of tax is taxable at the Irish corporation tax rate of 12.5% in
respect of trading income for the years 2003 and thereafter.
Non-trading income is taxable at 25%.
This excerpt taken from the ELN 6-K filed Mar 31, 2008. Taxation
of Corporate Income
We are a public limited company incorporated and resident for
tax purposes in Ireland. Under current Irish legislation, a
company is regarded as resident for tax purposes in Ireland if
it is centrally managed and controlled in Ireland, or, in
certain circumstances, if it is incorporated in Ireland. The
Taxes Consolidation Act, 1997 provides that a company that is
resident in Ireland and is not resident elsewhere shall be
entitled to have certain income from a qualifying patent
disregarded for tax purposes. The legislation does not provide a
termination date for this relief, although with effect from
1 January 2008, the amount of this income that is
disregarded for tax purposes is capped at €5 million
per year per group. A qualifying patent means a patent in
relation to which the research, planning, processing,
experimenting, testing, devising, designing, developing or
similar activities leading to the invention that is the subject
of the patent were carried out in an European Economic Area
state. Income from a qualifying patent means any royalty or
142 Elan
Corporation, plc 2007 Annual Report
Table of Contents
Shareholders’
Information
other sum paid in respect of the use of the invention to which
the qualifying patent relates, including any sum paid for the
grant of a licence to exercise rights under such patent, where
that royalty or other sum is paid, for the purpose of activities
that would be regarded under Irish law as the manufacture of
goods (to the extent that the payment does not exceed an
arms-length rate), or by a person who is not connected with us.
Accordingly, our income from such qualifying patents is
disregarded for tax purposes in Ireland. Any Irish manufacturing
income of Elan and its subsidiaries is taxable at the rate of
10% in Ireland until 31 December 2010. Any trading income
that does not qualify for the patent exemption or the 10% rate
of tax is taxable at the Irish corporation tax rate of 12.5% in
respect of trading income for the years 2003 and thereafter.
Non-trading income is taxable at 25%.
This excerpt taken from the ELN 20-F filed Feb 28, 2008. Taxation
of Corporate Income
We are a public limited company incorporated and resident for
tax purposes in Ireland. Under current Irish legislation, a
company is regarded as resident for tax purposes in Ireland if
it is centrally managed and controlled in Ireland, or, in
certain circumstances, if it is incorporated in Ireland. The
Taxes Consolidation Act, 1997 provides that a company that is
resident in Ireland and is not resident elsewhere shall be
entitled to have certain income from a qualifying patent
disregarded for tax purposes. The legislation does not provide a
termination date for this relief, although with effect from
January 1, 2008, the amount of this income that is
disregarded for tax purposes is capped at €5 million
per year per group. A qualifying patent means a patent in
relation to which the research, planning, processing,
experimenting, testing, devising, designing, developing or
similar activities leading to the invention that is the subject
of the patent were carried out in an European Economic Area
state. Income from a qualifying patent means any royalty or
other sum paid in respect of the use of the invention to which
the qualifying patent relates, including any sum paid for the
grant of a license to exercise rights under such patent, where
that royalty or other sum is paid, for the purpose of activities
that would be regarded under Irish law as the manufacture of
goods (to the extent that the payment does not exceed an
arms-length rate), or by a person who is not connected with us.
Accordingly, our income from such qualifying patents is
disregarded for tax purposes in Ireland. Any Irish manufacturing
income of Elan and its subsidiaries is taxable at the rate of
10% in Ireland until December 31, 2010. Any trading income
that does not qualify for the patent exemption or the 10% rate
of tax is taxable at the Irish corporation tax rate of 12.5% in
respect of trading income for the years 2003 and thereafter.
Non-trading income is taxable at 25%.
This excerpt taken from the ELN 6-K filed Mar 30, 2007. Taxation
of Corporate Income
We are a public limited company incorporated, and resident for
tax purposes, in Ireland. Under current Irish legislation, a
company is regarded as resident for tax purposes in Ireland if
it is centrally managed and controlled in Ireland, or, in
certain circumstances, if it is incorporated in Ireland. The
Taxes Consolidation Act, 1997, provides that a company that is
resident in Ireland and is not resident elsewhere shall be
entitled to have any income from a qualifying patent disregarded
for tax purposes.
140 Elan
Corporation, plc 2006 Annual Report
Table of Contents
Shareholders’
Information
The legislation does not provide a termination date for this
relief. A qualifying patent means a patent in relation to which
the research, planning, processing, experimenting, testing,
devising, designing, developing or similar activities leading to
the invention that is the subject of the patent were carried out
in Ireland. Income from a qualifying patent means any royalty or
other sum paid in respect of the use of the invention to which
the qualifying patent relates, including any sum paid for the
grant of a licence to exercise rights under such patent, where
that royalty or other sum is paid, for the purpose of activities
that would be regarded under Irish law as the manufacture of
goods (to the extent that the payment does not exceed an
arms-length rate), or by a person who is not connected with us.
Accordingly, our income from such qualifying patents is
disregarded for tax purposes in Ireland. Any Irish manufacturing
income of Elan and its subsidiaries is taxable at the rate of
10% in Ireland until 31 December 2010. Any trading income
that does not qualify for the patent exemption or the 10% rate
of tax is taxable at the Irish corporation tax rate of 12.5% in
respect of trading income for the years 2003 and thereafter.
Non-trading income is taxable at 25%.
This excerpt taken from the ELN 20-F filed Feb 28, 2007. Taxation
of Corporate Income
We are a public limited company incorporated, and resident for
tax purposes, in Ireland. Under current Irish legislation, a
company is regarded as resident for tax purposes in Ireland if
it is centrally managed and controlled in Ireland, or, in
certain circumstances, if it is incorporated in Ireland. The
Taxes Consolidation Act, 1997, provides that a company that is
resident in Ireland and is not resident elsewhere shall be
entitled to have any income from a qualifying patent disregarded
for tax purposes. The legislation does not provide a termination
date for this relief. A qualifying patent means a patent in
relation to which the research, planning, processing,
experimenting, testing, devising, designing, developing or
similar activities leading to the invention that is the subject
of the patent were carried out in Ireland. Income from a
qualifying patent means any royalty or other sum paid in respect
of the use of the invention to which the qualifying patent
relates, including any sum paid for the grant of a license to
exercise rights under such patent, where that royalty or other
sum is paid, for the purpose of activities that would be
regarded under Irish law as the manufacture of goods (to the
extent that the payment does not exceed an arms-length rate), or
by a person who is not connected with us. Accordingly, our
income from such qualifying patents is disregarded for tax
purposes in Ireland. Any Irish manufacturing income of Elan and
its subsidiaries is taxable at the rate of 10% in Ireland until
December 31, 2010. Any trading income that does not qualify
for the patent exemption or the 10% rate of tax is taxable at
the Irish corporation tax rate of 12.5% in respect of trading
income for the years 2003 and thereafter. Non-trading income is
taxable at 25%.
This excerpt taken from the ELN 6-K filed Mar 31, 2006. Taxation of corporate income
The Company is a public limited company incorporated, and
resident for tax purposes, in Ireland. Under current Irish
legislation, a company is regarded as resident for tax purposes
in Ireland if it is centrally managed and controlled in Ireland,
or, in certain circumstances, if it is incorporated in Ireland.
The Taxes Consolidation Act, 1997, provides that a company that
is resident in Ireland and is not resident elsewhere shall be
entitled to have any income from a qualifying patent disregarded
for taxation purposes. The legislation does not provide a
termination date for this relief. A qualifying patent means a
patent in relation to which the research, planning, processing,
experimenting, testing, devising, designing, developing or
similar activities leading to the invention that is the subject
of the patent were carried out in Ireland. Income from a
qualifying patent means any royalty or other sum paid in respect
of the use of the invention to which the qualifying patent
relates, including any sum paid for the grant of a licence to
exercise rights under such patent, where that royalty or other
sum is paid, for the purpose of activities that would be
regarded under Irish law as the manufacture of goods (to the
extent that the payment does not exceed an arms-length rate), or
by a person who is not connected with the Company. Accordingly,
the Company’s income from such qualifying patents is
disregarded for taxation purposes in Ireland. Any Irish
manufacturing income of the Company and its subsidiaries is
taxable at the rate of 10% in Ireland until 31 December
2010. Income arising from qualifying activities in our
Shannon-certified subsidiary is taxable at the rate of 10% in
Ireland until 31 December 2005. From 1 January 2006,
such income is taxable at a rate of 12.5%. Any trading income
that does not qualify for the patent exemption or the 10% rate
of tax is taxable at the Irish corporation tax rate of 12.5% in
respect of trading income for the years 2003 and thereafter.
Non-trading income is taxable at 25%.
This excerpt taken from the ELN 20-F filed Mar 30, 2006. Taxation
of Corporate Income
We are a public limited company incorporated, and resident for
tax purposes, in Ireland. Under current Irish legislation, a
company is regarded as resident for tax purposes in Ireland if
it is centrally managed and controlled in Ireland, or, in
certain circumstances, if it is incorporated in Ireland. The
Taxes Consolidation Act, 1997, provides
Table of Contents
that a company that is resident in Ireland and is not resident
elsewhere shall be entitled to have any income from a qualifying
patent disregarded for taxation purposes. The legislation does
not provide a termination date for this relief. A qualifying
patent means a patent in relation to which the research,
planning, processing, experimenting, testing, devising,
designing, developing or similar activities leading to the
invention that is the subject of the patent were carried out in
Ireland. Income from a qualifying patent means any royalty or
other sum paid in respect of the use of the invention to which
the qualifying patent relates, including any sum paid for the
grant of a license to exercise rights under such patent, where
that royalty or other sum is paid, for the purpose of activities
that would be regarded under Irish law as the manufacture of
goods (to the extent that the payment does not exceed an
arms-length rate), or by a person who is not connected with us.
Accordingly, our income from such qualifying patents is
disregarded for taxation purposes in Ireland. Any Irish
manufacturing income of Elan and its subsidiaries is taxable at
the rate of 10% in Ireland until December 31, 2010. Income
arising from qualifying activities in our Shannon-certified
subsidiary is taxable at the rate of 10% in Ireland until
December 31, 2005. From January 1, 2006, such income
is taxable at a rate of 12.5%. Any trading income that does not
qualify for the patent exemption or the 10% rate of tax is
taxable at the Irish corporation tax rate of 12.5% in respect of
trading income for the years 2003 and thereafter. Non-trading
income is taxable at 25%.
This excerpt taken from the ELN 6-K filed Apr 11, 2005. Taxation of corporate income The Company is a public limited company incorporated, and resident for tax purposes, in Ireland. Under current Irish legislation, a company is regarded as resident for tax purposes in Ireland if it is centrally managed and controlled in Ireland, or, in certain circumstances, if it is incorporated in Ireland. The Taxes Consolidation Act, 1997, provides that a company that is resident in Ireland and is not resident elsewhere shall be entitled to have any income from a qualifying patent disregarded for taxation purposes. The legislation does not provide a termination date for this relief. A qualifying patent means a patent in relation to which the research, planning, processing, experimenting, testing, devising, designing, developing or similar activities leading to the invention that is the subject of the patent were carried out in Ireland. Income from a qualifying patent means any royalty or other sum paid in respect of the use of the invention to which the qualifying patent relates, including any sum paid for the grant of a licence to exercise rights under such patent, where that royalty or other sum is paid, for the purpose of activities that would be regarded under Irish law as the manufacture of goods (to the extent that the payment does not exceed an arms-length rate), or by a person who is not connected with the Company. Accordingly, the Company’s income from such qualifying patents is disregarded for taxation purposes in Ireland. Any Irish manufacturing income of the Company and its subsidiaries is taxable at the rate of 10% in Ireland until 31 December 2010. Income arising from qualifying activities in our Shannon-certified subsidiary is taxable at the rate of 10% in Ireland until 31 December 2005. From 1 January 2006, it is anticipated, based on Irish legislation currently enacted, that such income will be taxable at a rate of 12.5%. Any trading income that does not qualify for the patent exemption or the 10% rate of tax is taxable at the Irish corporation tax rate of 12.5% in respect of trading income for the years 2003 and thereafter. Non-trading income is taxable at 25%. | EXCERPTS ON THIS PAGE:
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