Can I read Transfer pricing and intangibles : US and OECD arm's lenght distribution of operation profits from IP value chains on EtoBox?

Transfer pricing and intangibles : US and OECD arm's lenght distribution of operation profits from IP value chains by Oddleif Torvik is a nonfiction available to read on EtoBox.

What is Transfer pricing and intangibles : US and OECD arm's lenght distribution of operation profits from IP value chains about?

The transfer pricing of intangibles (patents, trademarks, etc.) is an important issue in international tax law, because it determines how superprofits generated by multinationals through the exploitation of valuable intellectual property (IP) in their worldwide value chains are allocated among the jurisdictions in which they do business. For decades, multinationals have used IP transfer pricing to shift taxable profits out of high-tax jurisdictions, causing serious base erosion. Both the United States and the OECD seek to combat these practices through mandatory transfer pricing rules aimed at ensuring that IP superprofits are taxed where the intangible value was created. The profit allocation process prescribed by these rules is analysed in this text. The first part of the process determines the amount of superprofits allocable to a unique and valuable IP (royalty amount). The US and OECD transfer pricing methods that govern this determination are analysed, applying a distinction between unique and non-unique value chain contributions, and it is observed that the methodology has evolved significantly over the years, from primarily relying on imprecise third-party benchmarking to m

Who reads Transfer pricing and intangibles : US and OECD arm's lenght distribution of operation profits from IP value chains?

Author

Oddleif Torvik

Publisher

I.B.F.D. Publications BV

Published

2018

Language

EN

ISBN

9789087224950

Category

nonfiction

Subjects

Law, Finance, Business