Page 39 - Strategic Tax Planning for Global Commerce & Investment

Strategic Tax Planning for Global Commerce and Investment

 Transferring accelerated tax depreciation
 Cross-border leasing provides the ability of

choosing the highest tax depreciation rates
 Moving ownership of assets to a place
where they are tax depreciable
 “Double –dip” leasing (creating an arbi-
trage between the tax rules of two coun-
tries, such that both the lessor and the

lessee are entitled to tax depreciation.

Tax Planning for Intellectual Property

Intellectual property (IP) includes the following:

 Trademarks
 Brands
 Designs

 Copyrights
 Computer software
 Technical know-how
 Patents

In today’s global business structures IP is an important element
of the entities’ balance sheet and thus, its location has a
material impact on the allocation of a multinational taxable
income among the various countries in which it operates.

From the tax perspective, other things being equal, a
multinational would prefer to own IP in a jurisdiction that
charges a relatively low effective tax rate on the income
generated by the IP.
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