Taxation of Intangibles

33 Pages Posted: 31 Jul 2020

See all articles by Jinyan Li

Jinyan Li

York University - Osgoode Hall Law School

Angelo Nikolakakis

Ernst & Young

Nathan Jin Bao

Osgoode Hall Law School

Date Written: February 27, 2019

Abstract

This paper examines the tax treatment of intangibles in Canada and recent developments internationally. It suggests that the special features of intangibles and the rapid rise of intangibles as value-drivers in the global economy may render existing tax rules inadequate in defining Canada’s tax base and/or competing for investment in research and development in Canada. Recent developments at the international level (such as the BEPS Project) and national level (such as US 2018 tax reform and changes in Japan, UK and China to implement BEPS recommendations) may point to some directions for Canada to consider.

Keywords: Intangibles, BEPS, Transfer Pricing, Digital Taxation, Patent Box; GILTI; FDII; BEAT; International Minimum Tax; Value Creation

Suggested Citation

Li, Jinyan and Nikolakakis, Angelo and Bao, Nathan Jin, Taxation of Intangibles (February 27, 2019). Osgoode Legal Studies Research Paper, Available at SSRN: https://ssrn.com/abstract=3664024 or http://dx.doi.org/10.2139/ssrn.3664024

Jinyan Li (Contact Author)

York University - Osgoode Hall Law School ( email )

4700 Keele Street
Toronto, Ontario M3J 1P3
Canada
416-736-5025 (Phone)

Angelo Nikolakakis

Ernst & Young ( email )

P.O. Box 4500
Station B
Montreal, Quebec H3B 5J3
Canada

Nathan Jin Bao

Osgoode Hall Law School ( email )

4700 Keele Street
Toronto, Ontario M3J 1P3
Canada

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