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The International Guide to the Taxation of Transfers of Technology


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IBFD - International Bureau of Fiscal Documentation Publications

The International Guide to the Taxation of Transfers of Technology

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Verlagsinformation :: Publisher's information

The International Guide to the Taxation of Transfers of Technology sets out the main aspects of domestic intellectual property law and other related non-tax rules, including non-tax investment premiums and subsidies for created or acquired technology. The tax aspects of domestic law concerning the creation, acquisition and transfer of technology to third parties are also addressed, as are topics, such as the contribution of intangible rights to the share capital of a company and the taxation of permanent establishments.

International tax issues, including tax treaties, are considered in subsequent sections, i.e.:

  • The tax position in the source state of a non-resident who receives income from intangibles, or for performing technical services, from the source state
  • The position in the state of residence of a person who receives this type of income from the source state
  • Finally, specific circumstances are considered, including build-operate transfers, turnkey projects, research companies, the pooling of technology, joint contracts, royalty packages and cross licences.

Main contents

  • Based on a standard outline developed in collaboration with Mr A.W. der Kinderen, former Director Corporate Fiscal Affairs at Philips International BV, each country chapter is divided into the following seven parts:
  • Overview of domestic rules
  • Tax treatment of technology exporter in an importing country - unrelated parties
  • Tax treatment of technology exporter in its own country - unrelated parties
  • Special cases
  • Transactions and arrangements between related parties or within the same legal entity
  • Compliance requirements
  • VAT and other (in)direct tax issues

Edited by Jan J.P. de Goede, Director Research and Development of the IBFD, and Dr Kevin Holmes, Principal Research Associate of the IBFD, The International Guide to the Taxation of Transfers of Technology provides a comparative study of all tax aspects relating to the transfer of technology.

Countries covered: the Czech Republic, Finland, India, Israel, Japan, New Zealand, South Africa, Switzerland, Norway and Sweden. To be included: Argentina, Australia, Belgium, Brazil, Denmark, Germany, Italy, Korea (ROK), the United Kingdom and the United States.

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