Transfer Pricing and Intangibles: US and OECD Arm’s Length Distribution of Operating Profits from IP Value Chains
Transfer Pricing and Intangibles: US and OECD Arm’s Length Distribution of Operating Profits from IP Value Chains by Oddleif Torvik
English | Jan 1, 2019 | ISBN: 9087224958 | 876 pages | PDF | 9 MB
English | Jan 1, 2019 | ISBN: 9087224958 | 876 pages | PDF | 9 MB
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. This book is suited for those that have an interest in transfer pricing analysis, e.g. students, lawyers, accountants and economists. The historical background of the current transfer pricing rules is explained, allowing for an “all-in-one” solution for catching up with the US and OECD transfer pricing development over the last decades.
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