Tax tips for IP owners

Multinational enterprises often allocate the ownership of IP among their group companies with more regard to legal rather than tax issues. Karen Hughes and Domenico Borzumato consider ways in which MNEs can manage their IP internationally so as to achieve greater tax efficiency.

A version of this article first appeared in the September issue of Managing Intellectual Property and also in the October issue of International Tax Review. Karen Hughes is a partner and Domenico Borzumato is Of Counsel in Lovells’ International Tax Practice, based respectively in our London and Rome offices.

Key points

• Transfer pricing rules require arm’s length royalty for IP