Transfer Pricing and Intangibles

More and more business models worldwide have come to rely intrinsically on intangible assets. Because transactions involving intangibles are particularly susceptible to the complexity surrounding transfer pricing rules, it is imperative that these transactions are conducted following a proper transfer pricing analysis. This book's comprehensive approach to the practical application of transfer pricing rules to intangibles opens a clear path to an effective and compliant application of the core principles, taking into consideration recent developments and providing valuable insights about industries that rely on specific intangibles.

With contributions from stakeholders who daily interact with transactions involving intangibles - representatives from multinational companies, governments, and academia, as well as advisors - the book provides in-depth analysis of such aspects as the following:

• introduction to transfer pricing of intangibles;

• transfer pricing of patents;

• transfer pricing of know-how and trade secrets;

• transfer pricing of trademarks, trade names and brands;

• transfer pricing of licences and similar limited rights in intangibles;

• transfer pricing of domain names and websites;

• transfer pricing of software and technology;

• transfer pricing of franchise agreements;

• transfer pricing of video and audio-visual materials.

   

Over eighty examples and numerous references to case law are highlighted throughout the book.

As a manual for understanding the distinct aspects of intangible assets that affect the application of transfer pricing rules, this book demonstrates in specific detail how careful attention to transfer pricing aspects of intangibles can avoid tax problems and forestall potential negative effects on a firm's reputation. It is a one-stop solution for tax lawyers, tax authorities, corporate in-house counsel, academics, the business community, and advisory firms, empowering them to confidently tackle the transfer pricing issues of transactions involving intangibles.