by Kluwer Law International, Sold and distributed in North, Central, and South America by Aspen Publishers in The Hague, Netherlands, Frederick, MD .
Written in English
Includes bibliographical references (p. 321-332) and index.
|Statement||by Michelle Markham.|
|LC Classifications||K1420.5 .M27 2005|
|The Physical Object|
|Pagination||xxi, 335 p. ;|
|Number of Pages||335|
|LC Control Number||2005301327|
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 Brand: Springer International Publishing. 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. 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 . instalment of the transfer pricing work mandated by the BEPS Action Plan. The Action Plan directs the OECD to address a number of transfer pricing issues, as follows: Action 8 – Intangibles Develop rules to prevent BEPS by moving intangibles among group members. This will involve (i) adopting a broad and clearly delineated.
pricing of intangible assets is closely linked to the overall transfer pricing system. Furthermore, most companies avoid influences of the transfer pricing system on performance measurement either by separating the books or making adjustments below the. KPMG report: Intangible property transfer pricing in an economic downturn KPMG report: Intangible property transfer pricing Transfers of intangible property between controlled parties arise in various contexts, including cost-sharing arrangements, ongoing license arrangements, sales of intangible property, and business restructurings. Intangibles constitute a substantial and major portion of transfer pricing issues on hand. They are extremely crucial in a Multinational (MNE) environment, however, their importance is often undermined to their inherent characteristics which may include easy mobility, misidentification and most importantly non-availability of set principles to assign values to such intellectual properties. Valuation of Intangibles for Transfer Pricing Purposes: Convergence of Valuations for Transfer Pricing Purposes with Valuation for Other Purposes Presentation to Working Party No. 6 of the Committee on Fiscal Affairs by: Dr. William F. Finan Susan Launiau Ma * * * Context.
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. The transfer pricing of intangibles. Markham, Michelle. Kluwer Law International pages $ Hardcover HD Description. This book provides a practical and technical guide to tax treatment and transfer pricing of intangibles such as patents, know how, copyrights, trademarks, exploitation rights etc. Starting with the issues involved in identification and taxation of transactions in intangibles and rights, the book goes on to discuss the nuances of finding the arm’s length range of royalty rates, IP transfer, . The transfer pricing of intangible properties has always been a significant issue for multinational enterprises (MNEs). The excellent idea devoted to this matter with the current drive of the OECD to counter tax base erosion is dim long over-due. Indeed, the case with transfer pricing is technically considered a neutral concept but erroneously.