The Resource Intangible revenues assigned to the developer and not to the funder lacking "development monitoring staff" : OECD transfer pricing anti-abuse rule clashes with economics of contracts

Intangible revenues assigned to the developer and not to the funder lacking "development monitoring staff" : OECD transfer pricing anti-abuse rule clashes with economics of contracts

Label
Intangible revenues assigned to the developer and not to the funder lacking "development monitoring staff" : OECD transfer pricing anti-abuse rule clashes with economics of contracts
Title
Intangible revenues assigned to the developer and not to the funder lacking "development monitoring staff" : OECD transfer pricing anti-abuse rule clashes with economics of contracts
Creator
Subject
Language
eng
Summary
The article is about the comparison of OECD transfer pricing rules on entitlement to intangible revenues with solutions suggested by the Economics of contracts and Principal-Agent models. The goal is to check whether the OECD's anti-abuse rule assigning intangible revenues to the developer and not to the funder, when funder lacks ability to monitor developing activity, actually enforces conditions that independent parties would agree upon, as it should be under the arm's-length principle (ALP). The conclusion is that the OECD rules clash with cconomic principles
Citation source
In: International tax journal. - Riverwoods. - Vol. 43 (2017), no. 6 (November-December) ; p. 37-43, 54-55
http://library.link/vocab/creatorName
Musselli, A
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • OECD Transfer Pricing Guidelines
  • transfer pricing
  • anti-avoidance
  • intangibles
  • arm's length principle
Label
Intangible revenues assigned to the developer and not to the funder lacking "development monitoring staff" : OECD transfer pricing anti-abuse rule clashes with economics of contracts
Instantiates
Publication
Label
Intangible revenues assigned to the developer and not to the funder lacking "development monitoring staff" : OECD transfer pricing anti-abuse rule clashes with economics of contracts
Publication

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