How often has your reaction to an IP valuation been “Wow, that’s high!” Then it is not surprising that this is also SARS’ standard reaction to IP valuations. Where IP valuations are prepared as part of a tax or structured finance transaction, it is essential ...
Over the years, many companies have valued their intellectual property (IP). Whether these valuations were for the purposes of determining a CGT base cost or claiming s11(gA) / s11(gC) allowances following acquisitions or mergers, taxpayers were typically interested in achieving the ...
The most appropriate methodology for determining a reasonable royalty rate is that which leaves the least number of questions unanswered. Unfortunately, databases such as royaltsource.com give insufficient information about the licensee to pass a thorough inquiry wholly intact. For ...
“Royalty stacking” results from an incorrect application of “the 25% Rule”. The best way of explaining this concept is by way of example: Opco uses trademarks, patents, designs, copyright and know-how in its business. Opco wishes sequentially to assign each ...
Nascent technology is typically valued using the cost approach. However, where the nascent technology is patentable, the cost approach does not account for value subsisting in the “monopoly rights”, and consequently grossly undervalues the intellectual property (IP). One ...
Nearly all intellectual property (IP) valuations prepared in South Africa for tax purposes use the relief from royalty methodology and “the 25% rule” for calculating the royalty. According to “the 25% rule”, the royalty rate is generally expected to fall within ...