Dr. Brian Keegan:

Let us say that I spend €1 million buying a patent, that I am manufacturing a product and that I make €100 profit for the sake of round figures. I can reduce that €100 by virtue of the €1 million I have spent on the patent but I am only allowed to reduce it so that there is some tax left in the charge. Of the €100 I have made on the product using the patent, I can only reduce that by 80% so there will always be €20 left in charge. When the intellectual property regime was introduced, that 80% restriction was there. It was removed some years later and was reinstated by virtue of the Finance Act 2017.