CRA was engaged by a Silicon Valley software company to prepare an economic analysis of the licensing of German registered patents for German withholding tax purposes. Following the top-down approach stipulated in the guidance from the German tax authorities, Rebel Curd and Robin Hart analyzed the specifics of the company’s intellectual property strategy to allocate a reasonable value to patents compared to software copyrights and trade secrets. Further analysis was performed on the composition of the patent portfolio, the vintage of software that each individual patent relates to, and the company’s paid vs. free software and applications.
ITR World Tax Guide 2025: Rebel Curd and David Kemp recognized
Congratulations to Rebel Curd and David Kemp for their recent recognition as “highly regarded” leaders in International Tax Review’s (ITR) 2025 World Tax...