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 formularly apportionment;
- transfer pricing documentation requirements;
- penalties for non-compliance;
- resolution of transfer pricing disputes; and,
- advance pricing agreements.