The Resource International profit allocation, intangibles and sales-based transactional profit split

International profit allocation, intangibles and sales-based transactional profit split

Label
International profit allocation, intangibles and sales-based transactional profit split
Title
International profit allocation, intangibles and sales-based transactional profit split
Creator
Subject
Language
  • eng
  • eng
Summary
Information technology has greatly changed the economy and intangible assets have become dominant value drivers of multinationals' business. Firm-specific intangibles challenge the time-honoured arm's length principle. The OECD's Action Plan on Base Erosion and Profit Shifting addresses this issue, aiming at an allocation of profits associated with the transfer and use of intangibles that is in accordance with value creation. The OECD proposals are in line with inter-nation equity, but may have undesired effects on the investment location decisions of multinationals. The authors take the OECD's proposals as a starting point and explore a sales-based transactional split of profits associated with intangibles to ensure both international investment tax neutrality and inter-nation equity. Sales-based taxation of intangible-related profits calls for an appropriate nexus in the sales jurisdiction. The authors examine possible avenues to expand the current permanent establishment rules to cover intangible-related business activities
Citation source
In: World tax journal. - Amsterdam. - Vol. 9 (2017), no. 1 ; p. 99-115
http://library.link/vocab/creatorName
  • Schreiber, U
  • Fell, L.M
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • allocation of profits
  • international taxation
  • fiscal neutrality
  • profit shifting
  • intangibles
  • PE
  • transactional profit methods
Label
International profit allocation, intangibles and sales-based transactional profit split
Instantiates
Publication
Note
20170323
Other control number
wtj_2017_01_int_1.html
Label
International profit allocation, intangibles and sales-based transactional profit split
Publication
Note
20170323
Other control number
wtj_2017_01_int_1.html

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