The Role of Tax in Choice of Location of Intellectual Property

Abstract

This article reports on, and draws conclusions from, an investigation designed to gain insights into the extent to which tax is a motivator when large multinational companies choose where to develop, and ultimately locate valuable intellectual property (IP). The research undertaken by the authors set out to 1) answer a broad question about specific business behaviour - what influences a multinational company’s choice of location of valuable - IP; 2) elicit attitudes towards Research and Development (R&D) tax credits as a stimulus for engagement in R&D; and 3) assess current schools of thought, tax rules and policy in light of the findings, to determine whether they are effective and desirable. The project arises from previous research by the team members and aims to advance understanding of the extent to which tax rules influence the choice of location of IP.

Keywords: Taxation, Intellectual Property, IP, tax credits, tax rules, IP location

JEL Classification: O34, E62, H2, H21, H24, H25, K34