Intellectual Property Rights From A Transfer Pricing Perspective
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Intellectual Property Rights From A Transfer Pricing Perspective
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Author : Isabel Verlinden
language : en
Publisher: Pricewaterhousecoopers
Release Date : 2004-01-01
Intellectual Property Rights From A Transfer Pricing Perspective written by Isabel Verlinden and has been published by Pricewaterhousecoopers this book supported file pdf, txt, epub, kindle and other format this book has been release on 2004-01-01 with categories.
The Transfer Pricing Of Intangibles
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Author : Michelle Markham
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2005-01-01
The Transfer Pricing Of Intangibles written by Michelle Markham and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2005-01-01 with Law categories.
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.
Mastering The Ip Life Cycle From A Legal Tax And Accounting Perspective
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Author : Isabel Verlinden
language : en
Publisher:
Release Date : 2018
Mastering The Ip Life Cycle From A Legal Tax And Accounting Perspective written by Isabel Verlinden and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2018 with categories.
The Dempe Concept And Intangibles
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Author : Karol Dziwinski
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2022-06-06
The Dempe Concept And Intangibles written by Karol Dziwinski and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2022-06-06 with Law categories.
Under the widely applied rules of the OECD Transfer Pricing Guidelines, allocation of the returns from the exploitation of intellectual property should be shared among all entities that contribute towards the profit-generating value of an intangible. This important book, in its detailed treatment of compliance with this principle – known as DEMPE (development, enhancement, maintenance, protection and exploitation) – describes exactly how both taxpayers and tax authorities can achieve an accurate assessment of transactions in order to arrive at an appropriate transfer pricing outcome. Analysing the legal, economic, and business management aspects of multinational enterprises activities, the book provides a comprehensive understanding of the DEMPE concept both in theory and in practice. Fully covered are such issues and topics as the following: role of the DEMPE concept within the framework of international tax law and transfer pricing; interplay of the DEMPE concept with the arm’s length principle; full description of each DEMPE function and analysis in the light of possible tax and transfer pricing consequences; modes of application of the DEMPE concept which can be directly implemented in practice; and additional tools (e.g., value chain analysis or RACI matrix) useful in applying the DEMPE concept. The book also provides the first in-depth analysis of the interplay between the DEMPE concept and the licence model in its various structural variations. Taking into account that intangibles amount to 84% of the market value of the S&P 500 companies and that over 80% of global trade transactions can be linked to value chains of multinational enterprises – and recognizing the scarcity of guidance heretofore on the application of the DEMPE concept – tax advisors, corporate counsels, tax authorities, and academics around the world are sure to appreciate and benefit greatly from this matchless and practical book.
The Dempe Concept And Intangibles
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Author : Karol Dziwinski
language : en
Publisher:
Release Date : 2022-06-06
The Dempe Concept And Intangibles written by Karol Dziwinski and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2022-06-06 with categories.
Under the widely applied rules of the OECD Transfer Pricing Guidelines, allocation of the returns from the exploitation of intellectual property should be shared among all entities that contribute towards the profit-generating value of an intangible. This important book, in its detailed treatment of compliance with this principle - known as DEMPE (development, enhancement, maintenance, protection and exploitation) - describes exactly how both taxpayers and tax authorities can achieve an accurate assessment of transactions in order to arrive at an appropriate transfer pricing outcome. Analysing the legal, economic, and business management aspects of multinational enterprises activities, the book provides a comprehensive understanding of the DEMPE concept both in theory and in practice. Fully covered are such issues and topics as the following: role of the DEMPE concept within the framework of international tax law and transfer pricing; interplay of the DEMPE concept with the arm's length principle; full description of each DEMPE function and analysis in the light of possible tax and transfer pricing consequences; modes of application of the DEMPE concept which can be directly implemented in practice; and additional tools (e.g., value chain analysis or RACI matrix) useful in applying the DEMPE concept. The book also provides the first in-depth analysis of the interplay between the DEMPE concept and the licence model in its various structural variations. Taking into account that intangibles amount to 84% of the market value of the S&P 500 companies and that over 80% of global trade transactions can be linked to value chains of multinational enterprises - and recognizing the scarcity of guidance heretofore on the application of the DEMPE concept - tax advisors, corporate counsels, tax authorities, and academics around the world are sure to appreciate and benefit greatly from this matchless and practical book.
Intellectual Property Valuation
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Author : Weston Anson
language : en
Publisher: American Bar Association
Release Date : 2005
Intellectual Property Valuation written by Weston Anson and has been published by American Bar Association this book supported file pdf, txt, epub, kindle and other format this book has been release on 2005 with Law categories.
"In this book, we attempt to cover some frequently asked questions on intellectual property and intangible assets and to engage in brief discussions on the subject of identifying value. We identify many of the main types of intellectual property and intangible assets. We also look at the primary, traditional, and not-so-traditional methods of valuing these assets and include case studies and various situations in which the valuation of these assets is required." -- from the Introduction, p. 3.
Introduction To Transfer Pricing
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Author : Jerome Monsenego
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2022-11-22
Introduction To Transfer Pricing written by Jerome Monsenego and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2022-11-22 with Law categories.
Transfer pricing refers to the pricing of cross-border intercompany transactions. Transfer prices influence the tax base of multinational enterprises, and thus also the fiscal revenues of the countries where they are doing business. The importance of transfer pricing has significantly expanded over time and culminated with the work of the OECD on Base Erosion and Profit Shifting (BEPS). With the globalisation of business activities, the need for States to prevent tax avoidance, and the risk of double taxation faced by multinational enterprises, transfer pricing has become a key question for multinational enterprises and tax administrations alike. Introduction to Transfer Pricing intends at providing a general introduction to the fundamentals of transfer pricing. The book is focused on explanations of the principles that apply, albeit to various extents, in most countries. Although the majority of these principles are provided by the OECD the views of other international organisations – in particular the United Nations and the European Union – are also taken into account. Moreover, the book illustrates the fundamentals of transfer pricing with concrete examples based on the structures often used by multinational enterprises when conducting cross-border business activities. Also included are relevant court cases from a variety of countries. Among the issues and topics covered are the following: the arm’s length principle in theory and practice; transfer pricing methods; intercompany transactions involving intangibles and financial transactions; common types of transfer pricing models; cross-border business restructurings; the substance requirement for transfer pricing purposes; attribution of profits to permanent establishments; and the prevention and resolution of transfer pricing disputes. This second edition was updated based on the 2022 OECD Transfer Pricing Guidelines and the 2021 UN Transfer Pricing Manual.
Transfer Pricing And Intangibles
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Author : Michael Lang
language : en
Publisher: Linde Verlag GmbH
Release Date : 2019-04-11
Transfer Pricing And Intangibles written by Michael Lang and has been published by Linde Verlag GmbH this book supported file pdf, txt, epub, kindle and other format this book has been release on 2019-04-11 with Law categories.
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.
Fundamentals Of International Transfer Pricing In Law And Economics
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Author : Wolfgang Schön
language : en
Publisher: Springer Science & Business Media
Release Date : 2012-02-15
Fundamentals Of International Transfer Pricing In Law And Economics written by Wolfgang Schön and has been published by Springer Science & Business Media this book supported file pdf, txt, epub, kindle and other format this book has been release on 2012-02-15 with Law categories.
The taxation of multinational corporate groups has become a major concern in the academic and political debate on the future of international taxation. In particular the arm’s length standard for the determination of transfer prices is under increasing pressure. Many countries and international bodies are now taking a closer look at the use of transfer prices for profit shifting and are exploring alternative mechanisms such as formulary apportionment for the allocation of taxing rights. With regard to this topic, this volume is the first to offer a concise analysis of transfer pricing in the international tax arena from an interdisciplinary legal and economic point of view. Fundamentals such as the efficient allocation of resources within multi-unit firms and distortions between different goals of transfer pricing as well as different aspects of it in tax and corporate law, the traditional OECD approach and practical aspects concerning intangibles, capital and risk allocation are covered by outstanding authors.
Valuation Of Intellectual Property And Intangible Assets
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Author : Gordon V. Smith
language : en
Publisher:
Release Date : 2000-04-19
Valuation Of Intellectual Property And Intangible Assets written by Gordon V. Smith and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2000-04-19 with Business & Economics categories.
While intellectual property plays an increasingly important role in the business world, it is difficult to quantify its economic and financial value. This guide to analytic techniques covers market value, accounting value, licensing and royalty rate and embryonic technology valuation.