Reduction in Corporate TAX of Software development based on AI

The price paid by the transferees does not correspond to the software itself, which in itself has little value, but to the secret scientific procedures that the software has implemented in it. These procedures are registered under the formula of industrial secret. The technology to be transferred incorporates an artificial intelligence system that involves a specialized advisory service that adapts case by case to the needs of the client. According to the modalities actually analyzed, in this case a contract has been signed by which the license to use temporarily or permanently a software containing procedures that allow theoretically determine various situations for marketing. In accordance with the case law of the Supreme Court (inter alia, STS of 30 May 2002; of 19 December 2002 or of 2 October 1999), it is essential to distinguish contracts for the assignment or licensing of know-how from contracts for technical assistance, both of which are distinct from contracts for the transfer of technology.