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Licensing a software management tool

Jane MacKay (Crowe Clark Whitehill) answers a query on the most advantageous way of licensing business software.
 

Question

 
My client runs a temp agency business through their own company TempCo. Their IT team has developed software which manages multiple sources of information about temps. The software allows us them to correctly report to and invoice their customers as well as providing them with the information to make correct tax and other filings. To date this software has only been used internally as a management tool. However my client believes it could have a far wider resource management application in the ‘gig’ economy. They could generate income from licensing the software separately from the provision of our temp staff services. What steps should be considered now in order to manage my client’s tax bill in the future?
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