PDF/EPUB Oddleif Torvik Ç Transfer Pricing and Intangibles: US and OECD Arm’s Ç

✎ Transfer Pricing and Intangibles: US and OECD Arm’s Length Distribution of Operating Profits from IP Value Chains (IBFD Doctoral Series Book 45) pdf ✐ Author Oddleif Torvik – Anglo-saxon.co The information in this book was last reviewed on 31 March 2018The transfer pricing of intangibles patents trademarks etc is an important issue in international tax law because it determines how superThe information in this book was last reviewed on 31 March 2018The 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 uniue and valuable IP royalty amount The US and OECD transfer pricing methods that govern this determination are analysed applying a distinction between uniue and non uniue value chain contributions and it is observed that the methodology has evolved significantly over the years from primarily relying on imprecise third party benchmarking tosubstance based approaches that seek to ensure results that adhere to the realistic alternatives of the controlled parties The second part of the profit allocation process determines to which group entity and thus indirectly also to which jurisdiction the amount of IP superprofits will be allocated The US and OECD intangible ownership provisions that govern this determination are analysed applying an original analytica.

transfer mobile pricing download intangibles: book oecd pdf arm’s pdf length book distribution free operating mobile profits pdf from kindle value download chains download ibfd epub doctoral free series pdf book kindle Transfer Pricing mobile and Intangibles: book and Intangibles: US and epub Pricing and Intangibles: kindle Pricing and Intangibles: US and book Transfer Pricing and Intangibles: US and OECD Arm’s Length Distribution of Operating Profits from IP Value Chains EpubThe process determines the amount of superprofits allocable to a uniue and valuable IP royalty amount The US and OECD transfer pricing methods that govern this determination are analysed applying a distinction between uniue and non uniue value chain contributions and it is observed that the methodology has evolved significantly over the years from primarily relying on imprecise third party benchmarking tosubstance based approaches that seek to ensure results that adhere to the realistic alternatives of the controlled parties The second part of the profit allocation process determines to which group entity and thus indirectly also to which jurisdiction the amount of IP superprofits will be allocated The US and OECD intangible ownership provisions that govern this determination are analysed applying an original analytica.

Leave a Reply

Your email address will not be published. Required fields are marked *