About recent trends in transfer pricing intangibles, gaar and beps. Guidance on transfer pricing aspects of intangibles. Beps project rewrites the book on transfer pricing. Guidance on transfer pricing aspects of intangibles addressing base erosion and profit shifting is a key priority of governments around the globe. The growing importance of the intangible assets in the global economy coupled with expanding international intrafirm trade, has meant that transfer pricing issues concerning intangibles have assumed critical importance for both the multi national enterprises as well as tax authorities.
The selection of the most appropriate transfer pricing method should be based on a functional analysis that provides a clear understanding of the mnes global business processes and how the transferred intangibles interact with other functions, assets and risks that comprise the global business. The oecds discussion draft looks at the issue of armslength pricing of intangible assets when the valuation of those assets is uncertain at the. The transfer pricing of intangibles wolters kluwer legal. It provides how internationally accepted transfer pricing rules were applied immediately prior to the beps project, and describes the principal. The nine articles in this collection each address a specific transfer pricing issue, providing an overview of the changes wrought by the new guidance and practical recommendations for taxpayers who will find. Under beps, transfer pricing professionals are already facing. Considering that the book is on tp and intangibles, i guess the lack of any available. The revisions to chapter vi of the transfer pricing guidelines contain some of the most significant changes adopted by the oecdg20 under its. Oecd releases new guidance on the application of the. This document contains revisions to the oecd transfer pricing guidelines to align transfer pricing outcomes with value creation in the area of.
The book considers the nature and scope of transfer pricing rules based on the arms length principle starting with an explanation of how the rules were created and and how they evolved over time. This book is suited for those that have an interest in transfer pricing analysis, e. Oecd proposes to allow hindsight in evaluating transfer pricing of. Some transfer pricing issues relating to intangibles are closely related to other issues that are to be addressed during 2015, most notably in relation to the. Oecd ilibrary guidance on transfer pricing aspects of. Globalisation has become a strategic practice for many business organisations in respect of services, manufacturing activities, the recent growth in offshored business services and development of intangibles.
The profit allocation process prescribed by these rules is analysed in this text. Guidance on transfer pricing aspects of intangibles oecd. Very useful book on transfer pricing in relation to intangibles and beps. The transfer pricing of intangibles markham, michelle on.
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