The purpose of resolutions Nos. 32 and 33 is to abolish the tax exemption for patent royalty income and the related exemption for distributions made by a company out of exempt patent royalty income. This is provided for in the four year plan and will yield an estimated €50 million in a full year. The measure takes effect from 24 November, the date of publication of the plan. The tax exemption for patent income which is available to Irish resident individuals and companies is provided for in section 234 and 141 of the Tax Consolidation Act 1997. Section 234 provides a tax exemption for royalty in respect of a qualifying patent, subject to an annual limit of €5 million. A qualifying patent is a patent in relation to which all the research, planning and development work leading to the patented invention was carried out in the State or in another country which is part of the European Economic Area.

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