Abstract
The interplay between cross-border migration and the application of national IP box regimes certainly triggers practical questions. Can a stepped-up entry value for intellectual property (IP) be accepted in the Destination State if the corresponding exit tax in the Departure State was (partially) exempt from corporate income taxes applying a national IP box regime? And does tax amortization on the stepped-up value negatively impact the application of the IP box regime in the Destination State?
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