On 22 October 2015, HMRC published for consultation its proposals for modifying the patent box regime with effect from 1 July 2016. These proposals are being implemented to tackle tax avoidance by multi-national enterprises. To benefit from the preferential corporation tax rate of the patent box (10%), a multi-national enterprises needs to carry out or sub-contract substantial research and development (R&D) activity within the UK to develop the IP.