This paper outlines five key elements that materially shape the outcome of cross border IP transfers. Each area is presented with practical financial modelling insights, examples and actionable insights:
Capital gains tax on IP transfers
Amortization benefit in Denmark
Deferred tax assets & liabilities (Group P&L and cash flow impact)
IP structuring and Danish principal model
Dividend distribution tax on repatriating cash.
Why this matters
In M&A settings, IP is often one of the most valuable assets transferred - but the tax and accounting implications of its relocation are often underestimated or deferred. This handbook provides a structured framework to evaluate IP transfer decisions end-to-end and can support early-stage structuring discussions between Tax, Finance, and Accounting teams.
Tax impact of IP transfer
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