Intangibles in the world of transfer pricing : identifying - valuing - implementing

Resource Information

The work Intangibles in the world of transfer pricing : identifying - valuing - implementing 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, Books.

Label

Intangibles in the world of transfer pricing : identifying - valuing - implementing

Contributor

• Heidecke, B
• Hübscher, M.C
• Schmidtke, R
• Schmitt, M

Subject

• ECJ case law
• R&D
• acquisition
• arm's length principle
• brand
• cash flow
• customs law
• fair market value
• intangibles
• intellectual property
• licensing
• merger
• profit split method
• transactional profit methods
• transfer pricing
• valuation
• value creation
• withholding tax

Language

eng

Summary

Intangible assets are becoming increasingly important as value drivers for multinational companies. It is a strategic question how to allocate intangibles within the multinational corporation. It needs to be defined by whom and under which conditions they can be utilized. Typical intellectual property (IP) migration models such as licensing, joint development and transferring are becoming a focal point within tax audits across the globe. Hence, defining an intangibles system that fulfils the tax requirements is of utmost strategic importance for multinational corporations. A central question is how to value intangibles in line with the arm's length principle as is required internationally for transfer pricing purposes. This book offers a road map for identifying, valuing and implementing intangibles for transfer pricing purposes under consideration of both the OECD and local perspectives. The book starts with an introduction to the role of intangibles in the world of transfer pricing including typical intangibles migration models. It describes common intangible assets across all types of industries, including e.g. automotive, consumer goods and software. Using several numerical examples, the book then covers state-of-the-art valuation methods including how to apply these methods in practice in a way consistent with the OECD Transfer Pricing Guidelines. The different country chapters provide country-specific guidance on the legal framework concerning intangible assets from a transfer pricing and valuation perspective. Finally, the book covers practical advice on the implementation of an intangible assets system

Geographic coverage

International

Index

no index present

Language note

English

Literary form

non fiction