Taxation of Intangibles
33 Pages Posted: 31 Jul 2020
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: Suggested Citation