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Tax Considerations for Franchise Businesses: Fees, Royalties, and Amortization Rules

Written by Yarik Yarosh, CPA (US & Canada) September 5, 2026 · FL CPA license AC61704 · CPA Ontario

Operating a franchise creates a distinct tax profile compared to starting an independent business. The largest upfront cost, the initial franchise fee, is not immediately deductible. Under IRC 197, the franchise fee is classified as a Section 197 intangible asset and must be amortized (deducted) ratably over 15 years (180 months), regardless of whether the franchise agreement runs for 10, 20, or 30 years. Ongoing royalty payments to the franchisor, however, are ordinary and necessary business expenses deductible in full when paid under IRC 162. The distinction between what is capitalized and what is currently deductible significantly affects the franchisee’s cash flow and taxable income, especially in the early years of operation when startup costs are highest and revenue is ramping up.

✓Key takeaway

Franchise expense tax treatment:

ExpenseTax TreatmentAuthority
Initial franchise feeAmortize over 15 years (IRC 197 intangible)IRC 197(d)(1)(F)
Ongoing royalties (% of sales)Fully deductible in year paidIRC 162
Advertising fund contributionsFully deductible in year paidIRC 162
Territory rights/exclusive area feeAmortize over 15 years (IRC 197)IRC 197(d)(1)(F)
Renewal feeAmortize over 15 years from renewal dateIRC 197
Transfer fee (paid when buying existing franchise from another franchisee)Part of purchase price; allocated per IRC 1060IRC 197 / IRC 1060
Training fees (initial, required by franchisor)Part of franchise fee if bundled; deductible if separately stated and optionalIRC 197 or IRC 162
Leasehold improvements required by franchisorDepreciate over 15 years (qualified improvement property, eligible for bonus depreciation)IRC 168(e)(6)
Equipment and fixtures (per franchisor specifications)Section 179 or bonus depreciationIRC 179 / IRC 168(k)
Signage (exterior, per brand standards)15-year depreciable life (land improvement) or IRC 197 if part of franchise agreementIRC 168
Build-out / construction costsDepreciate per asset class (39-year for commercial building, 15-year QIP, 5/7-year for equipment)IRC 168

IRC 197 amortization basics:

ElementRule
Period15 years (180 months), straight-line
Start dateMonth the franchise becomes available for use
ConventionMid-month (start deducting from the middle of the month placed in service)
Cannot accelerateEven if franchise agreement is terminated or expired before 15 years, the remaining basis continues amortizing over the original 15-year period (anti-churning rules)
Exception to accelerationComplete disposition of the franchise to an unrelated party allows remaining basis as a deduction

How are franchise costs deducted over time?

Related guides:

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Cite this page

Yarik Yarosh, CPA. "Tax Considerations for Franchise Businesses: Fees, Royalties, and Amortization Rules." Blue Cloud CPA, September 5, 2026. https://bluecloudcpa.com/guides/small-business-franchise-tax-considerations-fees-deductions

This guide is general information, not tax advice for your specific situation. Which points apply, and how, depends on your facts.