A significant number of countries now offer the critical operational pre-requisites for conducting research and development (R&D), i.e ., access to growing markets/customer base, access to talent, intellectual property protection, stable economy/government and IT infrastructure. This has led many countries to promote relocation of R&D operations to their country as part of their innovation-led economic development strategies. R&D tax incentives are an important component of these strategies and thus tax competition amongst European countries in respect of IP and related activities has become increasingly the norm.

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