Wanted: A Tax Code for the Digital Age – BusinessWeek – discusses how Amazon reduces its tax bill, compared to similar bricks-and-mortar companies in the US, and refers to transfers of IP offshore, probably to a Luxembourg entity and how transfer pricing assisted a reduction of 6 percentage points in Amazon’s effective tax rate.
From the Moscow Times – newspaper article which gives a general overview rather than detail, but it’s clear Russia have just as much trouble as the rest of the world in working out how to tax IP: “tax consequences of transactions involving goods, works and services leaves ambiguities for the taxation of transactions involving intellectual property”.
Allens Arthur Robinson: Publication: Focus: Tax disputes involving s25-90 interest deductions – ATO lose challenge to deductions on funding royalty stream acquisition
From IP Finance: Ireland’s tax proposals for IP investment and transactions
The reputed involvement of Senor I. P. Gato in the proposed international IP court (last paragraph in the link) should merit a second glance at the date, but the tax debates aren’t so funny.
From IP Finance: via Tech Transfer E-News comes news that the IRS is to pay increased attention to the tax status of revenue-generating activities of universities – including income from their IP licences.