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.
Highlights from 2025 and looking forward to 2026
In the United States, 2025 brought major activity in high profile transfer pricing disputes and reaffirmed how closely transfer pricing, tariffs, and customs...