The study on Tax Law of the Patent Licensing
Date Issued
2012
Date
2012
Author(s)
Hung, Yu-Shan
Abstract
Since the technology improvement, the intellectual property has become an important asset for a company, including the Patent and the relevant tax.
The research motive and thesis structure are explained as Chapter 1. On the Chapter 2, the definination of the patent licensing contract nature will be discussed, and the onus of tax, the changes of the subject matter of tax due to the option to the purpose, types and methods of patent licensing will be difined accordingly. Furthermore, a patent licensing transcation may be affected by tax measures of tax law. Thus, Chapter 3 collects relevant regulations, and discusses the relevant effect.
Base on the development of internationalization, it is a common transaction of patent licensing and only to discuss the internal tax law is no longer enough. For this reason, Chapter 4 will introduce the treaty of tax model on the income of the patent licensing, e.g. royalty.
Moreover, over than 60% of the patent licensing tansactions are conducted between the related companies. Therefore to get a clear point how to make the transfer pricing becomes an important issue. Chapter 5 will take a bird’s view on the transfer pricing of intangible asset and provide the review of the difficulty of the estimatation.
After synthesizing the above issues, the conclusion will be provided on Chapter 6.
Subjects
patent licensing
patent
license
royalty
tax measure
transfer pricing
international taxation
Type
thesis
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