The Italian Tax Authority has issued Ruling No. 120 of 24 April 2020 concerning whether certain payments received under an IP co-development and license agreement qualify as payments for the right to use IP, which could qualify for the 50% exemption provided under Italy's patent box regime.
The particular case for the Ruling involves a co-development and license agreement between two companies, Company Y and Company X, regarding a patented molecule used in pharmaceuticals. Under …