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

Resource Information

The work 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 represents a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Continuing Resources.

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

Creator

• Musselli, A

Subject

• OECD Transfer Pricing Guidelines
• anti-avoidance
• arm's length principle
• intangibles
• transfer pricing

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

Geographic coverage

North America

Language note

English