Intangibles in the World of Transfer Pricing

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Author :
Publisher : Springer
ISBN 13 : 9783319733319
Total Pages : 725 pages
Book Rating : 4.7/5 (333 download)

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Book Synopsis Intangibles in the World of Transfer Pricing by : Björn Heidecke

Download or read book Intangibles in the World of Transfer Pricing written by Björn Heidecke and published by Springer. This book was released on 2021-03-10 with total page 725 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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 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. Edited by leading transfer pricing and valuation experts in Europe, this comprehensive book offers practitioners an effective road map for identifying, valuing and implementing intangibles for transfer pricing purposes under consideration of both the OECD and local perspectives. It is therefore a must-have book for transfer pricing and valuation practitioners on all levels of experience. 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 written by local experts 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. This book offers invaluable guidance to practitioners seeking tools to apply the arm’s length principle in the world of intangibles.

The Transfer Pricing of Intangibles

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Author :
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041123687
Total Pages : 360 pages
Book Rating : 4.0/5 (411 download)

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Book Synopsis The Transfer Pricing of Intangibles by : Michelle Markham

Download or read book The Transfer Pricing of Intangibles written by Michelle Markham and published by Kluwer Law International B.V.. This book was released on 2005-01-01 with total page 360 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transactions involving intellectual property play an increasingly significant role in economic activity at every level from global to local, with particular challenges for taxation and revenue authorities. Moreover, the manifold complexities associated with identifying, valuing and transferring intangibles make this an issue requiring a creative review of existing transfer pricing methodologies and techniques. In this ground-breaking new study, Michelle Markham offers an in-depth examination of attitudes at the forefront of this rapidly evolving area of taxation law, focusing her work on a comparative analysis of the US, OECD, and Australian perspectives on the transfer pricing of intangible assets. The Transfer Pricing of Intangibles not only highlights the current problems encountered in inter-affiliate transactions of intangible property, but also attempts to offer a variety of solutions to these problems. Among the issues explored are the following: how the tax treatment of intangible in the context of transfer pricing has become a major international tax concern;definitional issues which are vital to an understanding of transfer pricing;application of the arm's length principle to intangible asset transactions;determination of legal and economic ownership of group intangible assets;intangible asset valuation and transfer;transfer pricing methodologies;global formulary apportionment;transfer pricing documentation requirements;penalties for non-compliance;resolution of transfer pricing disputes; and,advance pricing agreements Revenue authorities, multinational enterprise executives, and tax practitioners around the world will greatly appreciate the recommendations and solutions proposed in this knowledgeable and thoughtful book. Its acute sense of the opportunities and pitfalls of an ever-more-complex area of economic activity place it in a category of its own, of inestimable benefit to interested parties.

Transfer Pricing and Intangibles

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Author :
Publisher : Linde Verlag GmbH
ISBN 13 : 370941010X
Total Pages : 176 pages
Book Rating : 4.7/5 (94 download)

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Book Synopsis Transfer Pricing and Intangibles by : Michael Lang

Download or read book Transfer Pricing and Intangibles written by Michael Lang and published by Linde Verlag GmbH. This book was released on 2019-04-11 with total page 176 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing treatment of intangibles: Issues und developments In recent decades, intangibles have become one of the most relevant success factors for Multinational Enterprises (MNEs). Along with the increasing importance of intangibles for economies, their tax treatment has also been under scrutiny which includes inter alia respective transfer pricing issues. MNEs are seeking for the best ways to optimize their business arrangements with the related intangibles while, at the same time, getting the most tax-efficient treatment. On the other hand, tax authorities have become increasingly concerned with the ease that intangibles can be used in aggressive planning. These concerns have been noticed and addressed by the Organization for Economic Cooperation and Development which presented its main findings with respect to transfer pricing aspects of intangibles in Action 8 of the BEPS Project in 2015 and in the 2017 OECD Transfer Pricing Guidelines. This book is based on the outcomes of the presentations and discussions held during the WU Transfer Pricing Symposium, ‘Transfer Pricing and Intangibles: Current Developments, Relevant Issues and Possible Solutions’, that took place in October 2018 at the WU Vienna University of Economics and Business. The publication discusses the most important issues and recent developments related to transfer pricing treatment of intangibles. Starting with the definition of intangibles, it further deals with topics such as appropriate attribution of intangible-related profits, structuring of intangibles in MNEs, and proper valuation of intangibles. The authors, apart from providing a theoretical background to the discussed issues, also present case studies that show how certain issues can be approached in practice. Every chapter ends with a summary of the discussions held during the panels of the Transfer Pricing Symposium in which representatives of tax administrations, multinationals, and tax advisories presented their opinions on the issues at stake.

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017

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Author :
Publisher : OECD Publishing
ISBN 13 : 9264265120
Total Pages : 608 pages
Book Rating : 4.2/5 (642 download)

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Book Synopsis OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017 by : OECD

Download or read book OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017 written by OECD and published by OECD Publishing. This book was released on 2017-07-10 with total page 608 pages. Available in PDF, EPUB and Kindle. Book excerpt: This consolidated version of the OECD Transfer Pricing Guidelines includes the revised guidance on safe harbours adopted in 2013, as well as the recent amendments made by the Reports on Actions 8-10 and 13 of the BEPS Actions Plan and conforming changes to Chapter IX.

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022

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Author :
Publisher : OECD Publishing
ISBN 13 : 9264921915
Total Pages : 659 pages
Book Rating : 4.2/5 (649 download)

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Book Synopsis OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022 by : OECD

Download or read book OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022 written by OECD and published by OECD Publishing. This book was released on 2022-01-20 with total page 659 pages. Available in PDF, EPUB and Kindle. Book excerpt: In a global economy where multinational enterprises (MNEs) play a prominent role, governments need to ensure that the taxable profits of MNEs are not artificially shifted out of their jurisdiction and that the tax base reported by MNEs in their country reflects the economic activity undertaken therein. For taxpayers, it is essential to limit the risks of economic double taxation.

International Transfer Pricing

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Author :
Publisher :
ISBN 13 :
Total Pages : 288 pages
Book Rating : 4.3/5 ( download)

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Book Synopsis International Transfer Pricing by : Monica Boos

Download or read book International Transfer Pricing written by Monica Boos and published by . This book was released on 2003 with total page 288 pages. Available in PDF, EPUB and Kindle. Book excerpt: The valuation of intangibles as they are transferred from country to country but within multinational enterprise networks is major issue in taxation.

Transfer Pricing of Intangibles

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Author :
Publisher :
ISBN 13 :
Total Pages : 338 pages
Book Rating : 4.6/5 (862 download)

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Book Synopsis Transfer Pricing of Intangibles by : Emmanuel Shola Ayeni, PhD

Download or read book Transfer Pricing of Intangibles written by Emmanuel Shola Ayeni, PhD and published by . This book was released on 2020-09-14 with total page 338 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing is an ancient phenomenon with far more consequence in today's business environment. A significant volume of global trade nowadays consists of international transfers of tangibles: goods and services, capital (such as money) and intangibles (such as intellectual property) within an MNE group; such transfers are called "intra-group" transactions which continued to grow exponentially in all international transactions. When these transfers take place, the values of those transfers become significant both to the MNEs and various tax authorities. For tangible goods and services, the values are easily ascertainable and thus, making the transfer pricing methodology less arduous and the framework easily acceptable between the stakeholders. For intangibles, however, the valuation is more complex and the difficulties attendant to transfer pricing are more contentious. It is against this backdrop that this book examines the complexity of transfer pricing of intangibles and the attendant difficulties of the methodology to determining the arm's length principle of any transaction involving intangible assets. This study is an attempt to find ways to placate the frictions between tax authorities and multinational enterprises (MNEs) that Transfer Pricing of intangibles often brings. The objectives of this study are four-fold. First, it compares case laws from the United States and selected jurisdictions - - the United Kingdom, Australia, New Zealand, Italy, and Germany to identify the disparities and similarities of legal opinions on Transfer Pricing of intangibles. Second, it identifies any uniformity in the judicial interpretation of arm's length pricing of intangible assets. Third, it examines the focus of conflicts between tax authorities and multinational enterprises. Fourth, it explores any existing legal solutions that may help placate, or altogether, avoid the frictions between the stakeholders while formulating alternative dispute resolutions. The book provides empirical evidence of Transfer Pricing practices and the attendant difficulties by comparing the judicial review of the conflicts between the stakeholders in the United States, United Kingdom, Australia, Italy, and Germany to show the relative effectiveness, or lack thereof, of judicial intervention. Specifically, the book underscores the judicial uncertainty in the resolution of transfer pricing issue relating to intangibles and explores the use of augmented APAs as alternative resolution of Transfer Pricing issues between the stakeholders.

Transfer Pricing for Intangibles

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Author :
Publisher : Springer
ISBN 13 :
Total Pages : 94 pages
Book Rating : 4.F/5 ( download)

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Book Synopsis Transfer Pricing for Intangibles by : Fred de Hosson

Download or read book Transfer Pricing for Intangibles written by Fred de Hosson and published by Springer. This book was released on 1989-06-06 with total page 94 pages. Available in PDF, EPUB and Kindle. Book excerpt: Compilation of articles on the topic written by various authors, including: "A German tax practitioner's view on the White Paper" by Christoph Bellstedt; "The Italian approach to cost-contribution arrangements and possible discrepancies with the US White Paper on transfer pricing" by Guglielmo Maisto.

Recent Trends in Transfer Pricing

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Author :
Publisher :
ISBN 13 : 9789386432353
Total Pages : 504 pages
Book Rating : 4.4/5 (323 download)

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Book Synopsis Recent Trends in Transfer Pricing by : Ravi Kant Gupta

Download or read book Recent Trends in Transfer Pricing written by Ravi Kant Gupta and published by . This book was released on 2017 with total page 504 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Empirical Study of Transfer Pricing and the Intangibles

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Author :
Publisher :
ISBN 13 : 9781718191853
Total Pages : 320 pages
Book Rating : 4.1/5 (918 download)

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Book Synopsis Empirical Study of Transfer Pricing and the Intangibles by : Emmanuel Shola Ayeni

Download or read book Empirical Study of Transfer Pricing and the Intangibles written by Emmanuel Shola Ayeni and published by . This book was released on 2018-08-19 with total page 320 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing is an ancient phenomenon with far more consequence in today's business environment. A significant volume of global trade nowadays consists of international transfers of tangibles: goods and services, capital (such as money) and intangibles (such as intellectual property) within an MNE group; such transfers are called "intra-group" transactions which continued to grow exponentially in all international transactions. When these transfers take place, the values of those transfers become significant both to the MNEs and various tax authorities. For tangible goods and services, the values are easily ascertainable and thus, making the transfer pricing methodology less arduous and the framework easily acceptable between the stakeholders. For intangibles, however, the valuation is more complex and the difficulties attendant to transfer pricing are more contentious. It is against this backdrop that this book examines the complexity of transfer pricing of intangibles and the attendant difficulties of the methodology to determining the arm's length principle of any transaction involving intangible assets. This study is an attempt to find ways to placate the frictions between tax authorities and multinational enterprises (MNEs) that Transfer Pricing of intangibles often brings. The objectives of this study are four-fold. First, it compares case laws from the United States and selected jurisdictions - - the United Kingdom, Australia, New Zealand, Italy, and Germany to identify the disparities and similarities of legal opinions on Transfer Pricing of intangibles. Second, it identifies any uniformity in the judicial interpretation of arm's length pricing of intangible assets. Third, it examines the focus of conflicts between tax authorities and multinational enterprises. Fourth, it explores any existing legal solutions that may help placate, or altogether, avoid the frictions between the stakeholders while formulating alternative dispute resolutions. The book provides empirical evidence of Transfer Pricing practices and the attendant difficulties by comparing the judicial review of the conflicts between the stakeholders in the United States, United Kingdom, Australia, Italy, and Germany to show the relative effectiveness, or lack thereof, of judicial intervention. Specifically, the book underscores the judicial uncertainty in the resolution of transfer pricing issue relating to intangibles and explores the use of augmented APAs as alternative resolution of Transfer Pricing issues between the stakeholders.

Empirical Study of Transfer Pricing and the Intangibles

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Author :
Publisher :
ISBN 13 :
Total Pages : 338 pages
Book Rating : 4.6/5 (847 download)

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Book Synopsis Empirical Study of Transfer Pricing and the Intangibles by : Emmanuel Shola Ayeni Ph D

Download or read book Empirical Study of Transfer Pricing and the Intangibles written by Emmanuel Shola Ayeni Ph D and published by . This book was released on 2020-09-12 with total page 338 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing is an ancient phenomenon with far more consequence in today's business environment. A significant volume of global trade nowadays consists of international transfers of tangibles: goods and services, capital (such as money) and intangibles (such as intellectual property) within an MNE group; such transfers are called "intra-group" transactions which continued to grow exponentially in all international transactions. When these transfers take place, the values of those transfers become significant both to the MNEs and various tax authorities. For tangible goods and services, the values are easily ascertainable and thus, making the transfer pricing methodology less arduous and the framework easily acceptable between the stakeholders. For intangibles, however, the valuation is more complex and the difficulties attendant to transfer pricing are more contentious. It is against this backdrop that this book examines the complexity of transfer pricing of intangibles and the attendant difficulties of the methodology to determining the arm's length principle of any transaction involving intangible assets. This study is an attempt to find ways to placate the frictions between tax authorities and multinational enterprises (MNEs) that Transfer Pricing of intangibles often brings. The objectives of this study are four-fold. First, it compares case laws from the United States and selected jurisdictions - - the United Kingdom, Australia, New Zealand, Italy, and Germany to identify the disparities and similarities of legal opinions on Transfer Pricing of intangibles. Second, it identifies any uniformity in the judicial interpretation of arm's length pricing of intangible assets. Third, it examines the focus of conflicts between tax authorities and multinational enterprises. Fourth, it explores any existing legal solutions that may help placate, or altogether, avoid the frictions between the stakeholders while formulating alternative dispute resolutions. The book provides empirical evidence of Transfer Pricing practices and the attendant difficulties by comparing the judicial review of the conflicts between the stakeholders in the United States, United Kingdom, Australia, Italy, and Germany to show the relative effectiveness, or lack thereof, of judicial intervention. Specifically, the book underscores the judicial uncertainty in the resolution of transfer pricing issue relating to intangibles and explores the use of augmented APAs as alternative resolution of Transfer Pricing issues between the stakeholders.

Transfer Pricing Answer Book

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Author :
Publisher :
ISBN 13 : 9781402428456
Total Pages : 0 pages
Book Rating : 4.4/5 (284 download)

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Book Synopsis Transfer Pricing Answer Book by : David B. Blair

Download or read book Transfer Pricing Answer Book written by David B. Blair and published by . This book was released on 2017-05-07 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: The phenomena of increasingly global business enterprises with valuable intangible property expose companies to transfer pricing enforcement by different countries around the world. Many of these countries are increasingly aggressive in enforcing their local transfer pricing rules, as they attempt to protect their tax revenue base. To avoid double taxation of the same income in this environment, companies often are required to deal with the highly specialized, bilateral treaty-based competent authority process developed to prevent double taxation at a time when trade mainly involved only two established countries. Even more challenging today, companies and tax authorities increasingly are faced with the potential for multiple taxation of the same income, as supply chains cross many borders and as the tax authorities of emerging countries become players in the global taxation process, and the resulting stresses, strains, and limitations of the bilateral treaty-based competent authority process have become more apparent. In light of the high-dollar risks presented by the increased enforcement efforts of tax authorities worldwide, the complexity of the ever-changing, inherently uncertain transfer pricing standards, and the continually evolving business models of businesses adapting to the constantly changing global economy, companies need practical guidance to permit them to develop and defend their transfer pricing strategies. Transfer Pricing Answer Book gives companies such guidance by discussing all aspects of transfer pricing, from initially planning a transfer pricing strategy, to alternative ways to defend the strategy from attack by two or more tax authorities, to resolving a case before competent authorities, to bringing a transfer pricing case to court. The book's non-technical discussion is presented in a question and answer format that will appeal to readers regardless of their prior level of experience or familiarity with taxes in general and transfer pricing in particular. Transfer Pricing Answer Book is an invaluable resource for company executives and their advisors who are seeking to better understand this important area of tax law that has become such an important economic facet of so many businesses.

Transfer Pricing and Valuation in Corporate Taxation

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Author :
Publisher : Springer Science & Business Media
ISBN 13 : 0306482185
Total Pages : 294 pages
Book Rating : 4.3/5 (64 download)

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Book Synopsis Transfer Pricing and Valuation in Corporate Taxation by : Elizabeth King

Download or read book Transfer Pricing and Valuation in Corporate Taxation written by Elizabeth King and published by Springer Science & Business Media. This book was released on 2007-05-08 with total page 294 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer Pricing and Valuation in Corporate Taxation analyzes the disparities between both federal statutes and regulations, and r- ulations and administrative practice, in a highly controversial area of corporate tax policy: intra-company transfer pricing for tax p- poses. It addresses issues that often mean millions of dollars to in- vidual corporations, and a significant fraction of the federal gove- ment’s revenue base. These disparities between law, regulations, and administrative practice are concerning on a number of grounds. First, they - pose considerable economic costs by inducing corporations to engage in a variety of “rent-seeking” activities designed to reduce their - pected tax liabilities, and by requiring the IRS to devote still more to enforcement efforts that are very often futile. Second, they are in- ; herently undemocratic. Administrative practice is currently ad hoc by relying on dispute resolution procedures that can and do yield very different settlements on disputed tax issues from one case to another, the IRS often ends up treating similarly situated cor- rations very differently. Moreover, to the extent that the disp- ity between statute and implementation reflects the IRS’s failure to carry out Congress’ will, the laws passed by duly elected officials are effectively being superseded by administrative procedure, developed incrementally by individuals who are not answerable to an electorate.

OECD/G20 Base Erosion and Profit Shifting Project Guidance on Transfer Pricing Aspects of Intangibles

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Author :
Publisher : OECD Publishing
ISBN 13 : 9264219218
Total Pages : 134 pages
Book Rating : 4.2/5 (642 download)

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Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Guidance on Transfer Pricing Aspects of Intangibles by : OECD

Download or read book OECD/G20 Base Erosion and Profit Shifting Project Guidance on Transfer Pricing Aspects of Intangibles written by OECD and published by OECD Publishing. This book was released on 2014-09-16 with total page 134 pages. Available in PDF, EPUB and Kindle. Book excerpt: This document contains revisions to the OECD Transfer Pricing Guidelines to align transfer pricing outcomes with value creation in the area of intangibles.

Fundamentals of Transfer Pricing

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Author :
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403517247
Total Pages : 484 pages
Book Rating : 4.4/5 (35 download)

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Book Synopsis Fundamentals of Transfer Pricing by : Michael Lang

Download or read book Fundamentals of Transfer Pricing written by Michael Lang and published by Kluwer Law International B.V.. This book was released on 2021-06-18 with total page 484 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing is one of the most relevant and challenging topics in international taxation. Over the last century, nearly every country in the world introduced transfer pricing rules into their domestic legislation. Indeed, it was estimated that profit shifting generated by the improper application of transfer pricing rules has resulted in global tax losses worth USD 500 billion for governments – 20% of all corporate tax revenues. It is thus imperative that all tax professionals thoroughly understand the nature of transfer pricing and how the growing body of applicable rules works in practice. In this crucially significant volume, stakeholders from government, multinational companies, international organisations, advisory groups and academia offer deeply informed perspectives, both general and specific, on the practical application of transfer pricing rules, taking into consideration all the most recent developments. With approximately 160 practical examples and 90 relevant international judicial precedents, the presentation proceeds from general to more specialised topics. Such aspects of the subject as the following are thoroughly analysed: what is transfer pricing and the purpose of transfer pricing rules; the arm’s length principle and its application; the consequences of a transaction not being in accordance with the arm’s length principle; the transfer pricing methods; the mechanisms to avoid and resolve disputes; the transfer pricing documentation; the attribution of profits to permanent establishments; the transfer pricing aspects of specific transactions, such as services, financing, intangibles and business restructurings. The application of transfer pricing legislation is arguably the most difficult task that taxpayers and tax authorities around the world must face. With this authoritative source of practical guidance, government officials, tax lawyers, in-house tax counsel, academics, advisory firms, the business community and other stakeholders worldwide will have all the detail they need to move forward in tackling this thorny aspect of the current tax environment.

An Analysis of Adequate OECD Transfer Pricing Methods for Intangible Property

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Author :
Publisher : GRIN Verlag
ISBN 13 : 3668021937
Total Pages : 32 pages
Book Rating : 4.6/5 (68 download)

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Book Synopsis An Analysis of Adequate OECD Transfer Pricing Methods for Intangible Property by : Melanie Keller

Download or read book An Analysis of Adequate OECD Transfer Pricing Methods for Intangible Property written by Melanie Keller and published by GRIN Verlag. This book was released on 2015-07-24 with total page 32 pages. Available in PDF, EPUB and Kindle. Book excerpt: Bachelor Thesis from the year 2015 in the subject Economics - International Economic Relations, Management Center Innsbruck, language: English, abstract: Due to increased globalisation over the last years and enhanced activities of multinational enterprises (MNEs), intra-firm trade has become more and more important. Intra-firm trade is estimated to constitute about one third of the global trade; and about 50% of all exports within the member states of the Organisation for Economic Co-operation and Development (OECD) are intra-firm exports. In order to determine the expenses and revenues for the associated companies, transfer prices (TP) have to be set for the respective goods of intra-group transfers (Organisation for Economic Co-operation and Development [OECD]). Intra-group transfers can be defined as the transaction of tangible or intangible property from one entity of a MNE to another entity, considered as sale and “may apply to departments, divisions, subsidiaries, or affiliate business units” . A TP therefore is the internal monetary value im-posed on goods, services or unmanufactured material that is transferred within a MNE group. According to the OECD (2010) intra-firm transfers are likewise de-fined as controlled transactions (i.e., transactions between two associated enterprises).

Transfer Pricing and Intangibles

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Author :
Publisher :
ISBN 13 : 9789064762413
Total Pages : 688 pages
Book Rating : 4.7/5 (624 download)

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Book Synopsis Transfer Pricing and Intangibles by :

Download or read book Transfer Pricing and Intangibles written by and published by . This book was released on 2007 with total page 688 pages. Available in PDF, EPUB and Kindle. Book excerpt: