The Resource Using internal agreements to price intangible transfers

Using internal agreements to price intangible transfers

Label
Using internal agreements to price intangible transfers
Title
Using internal agreements to price intangible transfers
Creator
Subject
Language
eng
Summary
This article addresses the issues of comparability and adjustments for potential comparable uncontrolled transactions (CUTs), and how they can be used to reliably apply the comparable uncontrolled price method. In particular, multinational firms that are active participants in the marketplace for similar intangibles are likely to have potential CUTs in their licensing portfolios. Moreover, firms that are active in in-licensing and out-licensing these technologies often prepare financial analyses that are useful for determining profit potential and making reliable adjustments where necessary. This article discusses how these analyses can be performed and provides an example based on a hypothetical intercompany transaction involving intangible property
Citation source
In: Tax management transfer pricing report. - Arlington. - Vol. 23 (2014),
http://library.link/vocab/creatorName
Korenko, G.G
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • OECD Transfer Pricing Guidelines
  • transfer pricing
  • intangibles
  • comparable uncontrolled transaction method
  • CUP method
  • licensing
Label
Using internal agreements to price intangible transfers
Instantiates
Publication
Label
Using internal agreements to price intangible transfers
Publication

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      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
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