Court case raises questions about attribution of intangible-related profits A recent court case in Sweden has raised questions about how to attribute profits related to intangible assets, like trademarks. The case involved a Swedish company (AB) that paid a Maltese group company (Corp) for the use of a trademark [...]
Israeli Court Rules IP Value is Six Times Higher than Claimed Executive Summary The Tel Aviv District Court ruled in favor of the Israeli Tax Authorities (ITA), who claimed that the intellectual property (IP) which CA Software Israel Ltd. sold back in 2010 was worth ILS667m (rather than ILS111m [...]
Increased tax deduction for Research and Development expenses On 7 July 2022, Article 9(1)(d) of the Cyprus Income Tax (“IT’’) Law was amended to allow a tax deduction for expenditure incurred for scientific research and Research and Development (“R&D”). The said amendments were gazetted in the official Cyprus Government Gazette [...]
Incentives for Investment in Cypriot Innovative SMEs The Cyprus Income Tax Law includes tax incentives for individuals who are tax residents of Cyprus and invest in innovative small and medium-sized enterprises (SMEs). The incentives, which were originally implemented in 2017 and have been extended multiple times, aim to encourage [...]
Changes on the taxation of intangible assets On 17 July 2020, the Cypriot House of Representatives approved a bill amending the Income Tax Law introducing changes with respect to the taxation of intangible assets. The changes relate to all types of capital-nature intangible assets, other than Intellectual Property (“IP”) [...]
Disposal of IP Taking advantage of the Cypriot IP Regime The Issue A Cyprus company was the owner of valuable mobile software (IP) used by millions of users in Central Europe. The IP was owned, managed and exploited via a Cyprus company. Once [...]
Franchise expansion to the US Taking advantage of the Cyprus-US double tax treaty The Issue Our client is the owner of a multinational restaurant franchise with licensing arrangements and activities in more than 19 countries. He decided to expand the franchise activities to [...]
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