Transferring Intellectual Property via Offshore Permanent Establishments: Lessons from BGH and IPAB Rulings

Introduction In the present times, Offshore Permanent Establishments are leading in the field of international taxation and intellectual property laws. Several multinational and transnational companies including startups have started to transport their intellectual property assets, commonly trademark, patent, copyright and design into offshore permanent establishments. This choice to transfer PEs is a strategic reaction to increased taxation and open ended research and development projects....