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Taxation

IP licensing arbitrage tax section 23I

R&D tax incentive opened-up to double-dipping

Forming technology start-ups

IP tax review (Finweek)

Alchemy: converting the nature of assets in a sale of business

Treasury - request for IP submissions re Tax Act / Excon

s23I – Tax anti-avoidance measures for licensing

Taxation of royalty receipts in terms of "outgoing licences"

Beneficial ownership of royalties

s11D Guideline (R&D tax incentive)

s11D - Financing R&D equipment

s11D - deductibility of know-how related R&D

s11D - Limitation of claims

Beware those transfer pricing contraventions

IP tax allowances - caution re recent amendments

Nature of royalty payments after the BP case

International licensing structures

Allowances for the acquisition of intellectual property and software

Deduction of upfront royalty payments

Deduction of intellectual property related litigation expenses

Accrual of royalty payments

Transfer pricing

“Roll-up” international licence agreements

When is the payment for software a royalty?

Is the “licence” in substance a sale or a licence?

PCT filings – use of the rebate

Research & Development preparing to ride high on a gift horse

Expatriated intellectual property - Taxation of royalties