The French tax authority has issued guidance on the optional regime for patents and similar intangible assets, which was amended with effect from 1 January 2019 to comply with BEPS Action 5.
The amended regime includes the application of the modified nexus approach to provide that the amount of income qualifying for the regime is limited to the amount resulting from the ratio of R&D expenditure incurred by the taxpayer and unrelated parties for the creation/development of the asset wit…