Why this book?
Creativity, imagination, collaboration and entrepreneurship are the seeds of brands, trademarks, patents, algorithms and know-how, to name just a few potentially valuable attributes of successful ventures. These are constantly created, exploited and disposed of during the IP life cycle, from the cradle to the grave. Companies’ investment decisions centre around where to locate brainpower and infrastructure in an eternal quest to capture the sweet spot of the global value chain. The question is how to manage, let alone price, transactions where the “ungraspable” is at stake.
Mastering the IP Life Cycle from a Legal, Tax and Accounting Perspective provides an in-depth guide to managing IP rights. The book begins with general chapters that examine, among other topics, the increased importance of IP, the significance of R&D and branding, and the protection and exploitation of IP. Each stage of the IP life cycle is discussed in detail, including such issues as the valuation, migration and extinction of such rights. The general introductory chapters are followed by 48 country chapters covering jurisdictions from across the globe. Each country chapter provides an overview of legal and tax definitions, expenditure for the development or acquisition of IP rights, income characterization, outbound royalty payments, tax treatment of the disposal of IP, specific cross-border transfer provisions, CFC rules, exit taxes, grants and incentives to stimulate inward IP investment, registration or stamp duties on transfer or license, and indirect taxes. With the aim of encouraging a harmonized approach to addressing intangibles, the standardized outline allows easy comparison between countries.
The authors draw upon their own experiences and knowledge to share their insights and to provide numerous examples that guide the reader through the full IP life cycle. With its pragmatic approach, this book is a valuable reference for all those seeking to grasp a true understanding of IP rights, particularly from a tax and legal perspective.
Isabel Verlinden is a Brussels-based International Tax Partner heading up PwC’s Global Transfer Pricing practice. She has gathered first-hand knowledge of the TP challenges faced by companies that operate across the globe in over 25 years of working for PwC (and its legacy firms) in Brussels and Washington, DC.
Anuschka Bakker is the Manager of the Transfer Pricing and Specialist Knowledge Group of IBFD in Amsterdam. In addition, she acts as the Cluster Manager for the transfer pricing courses offered by IBFD International Tax Training. Prior to joining IBFD, she worked for Ernst & Young and PricewaterhouseCoopers. She has many years of experience in international taxation issues, of which the last 12 have been dedicated to transfer pricing. Ms Bakker also lectures and publishes regularly on a wide variety of transfer pricing-related topics. Further, Ms Bakker speaks at transfer pricing conferences around the world.