Transfers of Technology: A Basic Primer On Tax Considerations

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“The objective of this paper is to introduce managers of R&D operations to tax issues that must be considered when technology is transferred across international boundaries within the same company. The tax implications are often misunderstood or even overlooked in the technology transfer process. The paper explains how countries seek to tax their fair share of the income earned inside their borders. Since the amount of income earned depends on the price for technology paid by one part of a company to another, this “transfer price” is of keen interest to the tax authorities. To preserve their tax bases, therefore, countries establish rules to regulate the international transfer of goods and services, including technology, between related parties. This paper provides an overview of the economic principles underlying these rules, and illustrates their application with a series of examples.”

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