Corporate Taxes, IP License

The Diverted Profits Tax & Royalty Withholding Tax: Impacts on Intellectual Property Licenses and Transactions

J.S. Held on 2/21/2024

The Diverted Profits Tax (DPT) has been a significant area of focus for taxpayers and tax authorities in the UK and Australia. The tax targets specific situations in which taxable profits are alleged to have been “diverted”...more

German federal ministry of finance requires disclosure in cases of licensing of IP registered in Germany

BCLP on 3/22/2022

Even without a German nexus, in cases of a licensing of right registered in Germany an application/disclosure before 30 June 2022 might be necessary. ..According to the German Federal Ministry of Finance (BMF) the...more

German IP Withholding Tax

White & Case LLP on 11/16/2020

On November 6, 2020, the German Federal Ministry of Finance issued a decree addressing certain open questions relating to foreign taxpayers’ obligation to submit tax filings for royalty income derived from intellectual...more

EU General Court strikes a blow to Commission approach to fiscal State aids in the Apple tax case

White & Case LLP on 7/20/2020

The General Court has upheld a challenge to a 2016 Commission decision that had required Ireland to recover €13.2 billion in illegal State aid from Apple, on account of alleged preferential tax treatment for the...more

Draft French Finance Bill for 2019 Reveals Significant Tax Amendments

Jones Day on 10/8/2018

The Situation: The first draft of the French government's finance bill for 2019 contains several significant amendments likely to affect key French tax regimes, as well as past and current transactions. The Development:...more

US: Amazon wins tax dispute over cross-border IP transfer, but favorable tax treatment may no longer be available

Hogan Lovells on 6/9/2017

Earlier this year in Amazon v. Commissioner, 148 T.C. No. 8 (March 23, 2017), the U.S. Tax Court issued a 207-page decision largely upholding Amazon’s tax treatment of an intellectual property transfer in 2005 and 2006 from...more

MoFo New York Tax Insights - Volume 7, Issue 8

Morrison & Foerster LLP on 8/5/2016

ALJ holds that a Retailer Must File on a Combined Basis with a Related Intellectual Property Licensing Company - A New York State Administrative Law Judge has held that a retailer must file combined corporate franchise...more

The European Commission’s New Pandora’s Box – Reopening Final Tax Rulings as a Form of “State Aid”

Sheppard Mullin Richter & Hampton LLP on 10/23/2015

In Short - The European Commission (Commission) has adopted a decision on 21 October 2015 on the tax rulings – also referred to as “comfort letters” – granted by Luxembourg to Fiat Finance and Trade (FFT) and by The...more

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