International Taxation of Intellectual Property provides an expert examination of the main transactions that an IP or tax professional conducts. Practical and detailed, this book focuses on the key topics that corporate practitioners face. Featuring expert guidance, International Taxation of Intellectual Property also provides thorough analysis of significant country differences to important topics.
The major themes or transactions covered in the book include:
Creating IP
Incentives and other tax advantages in major jurisdictions - with expert guidance on where is good from a protection point of view (conventions, strength of IP law etc). Tax treatment of costs of creation - and research and development on abortive/unsuccessful projects. Any tax advantages are also compared with accountancy treatment.
Exploiting IP
How royalty flows are taxed in major jurisdictions. Tax treaty quirks and issues when receiving or paying royalties.
Acquisition of IP
Any tax incentives. How tax treatment compares with accounting treatment. Funding structures.
Group Issues
Useful group structures for IP intensive business - creating IP, and/or holding IP, and/or exploiting IP as part of the overall business model. Flexibilities or otherwise in tax treaties and domestic law in various jurisdictions. Transfer pricing opportunities and pitfalls - valuation, competing tax authorities, licensing structures.
Contributors include CMS Bureau Francis Lefebvre, Collas Day, Hogan and Hartson, KPMG, Pump Court Tax Chambers and Wragge & Co.
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