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Vol 23 No 2 Feb/March 2018

Book of the Month

Cover of The UK Supreme Court Yearbook Volume 8: 2016-2017 Legal Year

The UK Supreme Court Yearbook Volume 8: 2016-2017 Legal Year

Edited by: Daniel Clarry
Price: £120.00

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The Transfer Pricing of Intangibles

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ISBN13: 9789041123688
ISBN: 9041123687
Published: September 2005
Publisher: Kluwer Law International
Country of Publication: The Netherlands
Format: Hardcover
Price: £151.00

Despatched in 10 to 12 days.

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 methodologies and techniques.

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-affiliate transactions of intangible property, but also attempts to offer a variety of solutions to these problems. Among the issues explored are the following:-

  • how the tax treatment of intangible in the context of transfer pricing has become a major international tax concern
  • definitional issues which are vital to an understanding of transfer pricing
  • application of the arm s length principle to intangible asset transactions
  • determination of legal and economic ownership of group intangible assets
  • intangible asset valuation and transfer
  • transfer pricing methodologies
  • global formulary apportionment
  • transfer pricing documentation requirements
  • penalties for non-compliance
  • resolution of transfer pricing disputes
  • advance pricing agreements

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