Irish tax law provides a total exemption from tax for income derived from “qualifying patents” received by a person resident in Ireland and not resident in any other country. A “qualifying patent” is defined as a patent in relation to which the research, planning, processing, experimenting, testing, devising, designing, developing, or similar activity leading to the invention that is the subject of the patent was carried out in Ireland. Further, distributions by Irish resident companies of income, which falls within the exemption, are also exempt for tax purposes. A qualifying patent does not have to be an Irish patent.