Abstract

The underlying scenario of this thesis is the existence and extent of liability to tax on income arising from patent royalties in cross-border transactions. A quantitative method and associated model are developed that compare and contrast the susceptibility of identified legal frameworks, considered in pairs, to jurisdictional arbitrage regarding this income. The jurisdictions of Australia and the United States engaged in cross-border transactions with Ireland are examined.

Year Manuscript Completed

2014

Keywords

Patent laws and legislation; Patents (International law); PatentsTaxation United States; PatentsTaxation Australia; PatentsTaxation Ireland.

Primary Language of Manuscript

EN

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