Taxation and Revenue

Taxation of Intellectual Property (IP) and Intangibles Training Course

Introduction

Taxation of Intellectual Property (IP) and Intangibles Training Course provides a comprehensive and practical understanding of how intellectual property and intangible assets are valued, managed, transferred, and taxed in both domestic and cross-border settings. It examines the economic and legal characteristics of key intangibles such as patents, trademarks, copyrights, software, brand value, goodwill, and proprietary technologies. Participants will explore how these assets contribute to business profitability and how tax authorities assess and regulate them for compliance and revenue purposes.

The course delves deeply into transfer pricing principles, focusing on how profits derived from intangibles are allocated among related entities across jurisdictions. It highlights the complexities of determining arm’s-length values for IP transfers and licensing arrangements, especially within multinational enterprises. Participants will also learn about international frameworks, including OECD Transfer Pricing Guidelines and BEPS (Base Erosion and Profit Shifting) Action Plans, which aim to ensure transparency and fair taxation of intangible income. In addition, the program discusses the strategic use of IP in global business restructuring, emphasizing tax planning, optimization, and compliance challenges in the evolving digital and knowledge-based economy. By the end, attendees will have the expertise to apply effective IP tax strategies and navigate emerging international tax standards.

Programme Curriculum

Taxation of Intellectual Property (IP) and Intangibles Training Course

Introduction

Course Objectives

By the end of the course, participants will be able to:

Understand the nature and classification of intellectual property and intangibles.
Analyze how IP generates taxable income across jurisdictions.
Apply OECD transfer pricing guidelines to intangible assets.
Evaluate IP ownership structures for tax efficiency.
Understand cost-sharing arrangements and IP migration strategies.
Identify BEPS risks related to intangible transfers.
Assess valuation techniques for IP assets.
Manage compliance and documentation for IP-related transactions.
Apply tax treaty provisions to IP royalties and licensing.
Examine the impact of global tax reform on IP taxation.
Structure IP holding and financing arrangements effectively.
Understand anti-avoidance and CFC rules on intangible income.
Develop strategies for aligning tax and business value creation.

Target Audience

This course is suitable for:

Tax professionals and advisors
Corporate finance managers
Accountants and auditors
Legal and compliance officers
Transfer pricing specialists
Multinational corporate executives
Revenue and tax authority officials
Intellectual property managers

Course Duration: 5 days

Course Modules

Module 1: Overview of Intellectual Property and Intangibles

Definition and types of IP (patents, trademarks, copyrights, etc.)
Economic value of intangible assets
IP ownership and income generation
Tax implications of IP creation and exploitation
Legal protection frameworks for IP
Case study: Taxation of royalties from patents

Module 2: IP Valuation and Transfer Pricing

OECD guidance on transfer pricing for intangibles
Methods for IP valuation (comparable, cost, income approaches)
Arm’s length principle and DEMPE functions (Development, Enhancement, Maintenance, Protection, Exploitation)
Intra-group transactions and pricing of intangibles
Documentation and compliance requirements
Case study: Valuation of brand intangibles in a multinational group

Module 3: IP Ownership Structures and Tax Planning

Centralized vs. decentralized IP ownership
IP holding companies and favorable jurisdictions
Royalty routing and licensing structures
Substance and beneficial ownership requirements
Managing double taxation on intangible income
Case study: Structuring an IP holding company in Ireland

Module 4: BEPS, Anti-Avoidance Rules, and IP Migration

BEPS Actions 5 and 8–10 and their impact on IP taxation
Harmful tax practices and nexus approach
Controlled Foreign Company (CFC) rules
Anti-hybrid and substance requirements
IP migration and tax exit charges
Case study: Re-domiciling IP to a compliant jurisdiction

Module 5: Taxation of Royalties and Licensing Income

Treatment of royalties under domestic and treaty laws
Withholding tax implications on cross-border royalties
Royalty deduction and exemption rules
Taxation under OECD and UN Model Conventions
Impact of digitalization on IP royalties
Case study: Royalty payments under multiple tax treaties

Module 6: Intangibles in the Digital Economy

Role of IP in digital business models
Tax challenges in cloud computing and software licensing
Digital services and user-based intangibles
Interaction between DST and IP taxation
Emerging international reform initiatives
Case study: IP and tax implications in digital platforms

Module 7: Global Tax Reform and IP Strategies

OECD Pillar One and Two and their effects on IP income
Global minimum tax (GloBE) and nexus redefinition
IP-driven profit allocation challenges
Managing tax risks under new global frameworks
Designing tax-efficient IP value chains
Case study: Multinational restructuring after BEPS 2.0

Module 8: Compliance, Risk Management, and Best Practices

IP tax documentation and reporting obligations
Managing disputes with tax authorities
Integrating IP tax strategy with corporate governance
Risk assessment and internal audit mechanisms
Future trends in IP taxation and innovation incentives
Case study: Audit defense strategies for IP-rich entities

Training Methodology

Expert-led presentations and discussions
Real-world IP and tax case studies
Group workshops and simulations
Practical exercises on IP valuation and structuring
Interactive Q&A and scenario-based learning
Continuous feedback and performance assessment

Register as a group from 3 participants for a Discount

Send us an email: info@fineskilltrainingcenter.org or call +254769199797

Certification

Upon successful completion of this training, participants will be issued with a globally- recognized certificate.

Tailor-Made Course

We also offer tailor-made courses based on your needs.

Key Notes

a. The participant must be conversant with English.

b. Upon completion of training the participant will be issued with an Authorized Training Certificate

c. Course duration is flexible and the contents can be modified to fit any number of days.

d. The course fee includes facilitation training materials, 2 coffee breaks, buffet lunch and A Certificate upon successful completion of Training.

e. One-year post-training support Consultation and Coaching provided after the course.

f. Payment should be done at least a week before commence of the training, to Fineskill Training Center account, as indicated in the invoice so as to enable us prepare better for you.

Programme Fee

Duration: 5 Days

Method: Online or Physical

Online Price: $1,000

Physical Price: $1,500

Certification: Accredited Certificate

View Available Dates 📄 Download Course Outline (PDF)

Available Sessions

Location

Month

Year

Oct 19 2026

19 Oct — 23 Oct 2026

💻 Online / Virtual session

Online $1,000