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Tax issues for asset-centric biotechnology company

Question

 
My client is a loss-making UK biotechnology company with two drugs A and B at early stages of development. The venture capital investors in the company have differing opinions about the prospects of these drugs and one investor has decided to stop funding the B programme altogether. Investors and management have agreed on an ‘asset-centric’ approach with the B programme moved into a sister Newco. Going forward the investors will only have equity stakes in the programmes they are funding. The staff and resources will remain in the legacy company. What key tax issues need to be considered?
 

Answer

 
The biotechnology industry is one of extremes where the likelihood of failure is high development timescales are long and losses are large. However the ultimate exit...

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