Licence income in the UK
VAT on data licences, and data as a UK intangible
A UK company licensing its data asks two tax questions: where the supply is made for VAT, and whether the data is an intangible asset for corporation tax.
Licensing to a business
HMRC's Notice 741A says general rule services supplied business to business are supplied where the customer belongs, and that a UK supplier whose place of supply is the UK charges UK VAT regardless of where the customer belongs.
Source: Data licence income tax rules
Licensing to consumers
HMRC's guidance on digital services says the place of supply of a cross-border digital service to a consumer is the consumer's location, determined by where the consumer usually lives, and Schedule 4A of the Value Added Tax Act 1994 holds the special rules for electronically supplied services.
Source: Data licence income tax rules
Data as an intangible asset
Section 712 of the Corporation Tax Act 2009 gives an intangible asset the meaning it has for accounting purposes and says it includes intellectual property, and HMRC's manual at CIRD11150 reads that as including, not confining the term to, intellectual property.
Source: Data licence income tax rules
More from this site
The platforms a licence can be sold through are on data monetisation platforms.