About this book:
Transfer Pricing and Intangibles is a unique book with a comprehensive approach to the practical application of transfer pricing rules to intangibles that opens a clear path to an effective and compliant application of the core principles, taking into consideration recent developments and providing valuable insights about industries that rely on specific intangibles. More and more business models worldwide have come to rely intrinsically on intangible assets. Because transactions involving intangibles are particularly susceptible to the complexity surrounding transfer pricing rules, these transactions must be conducted following a proper transfer pricing analysis.
What’s in this book:
With contributions from stakeholders who interact daily with transactions involving intangibles – representatives from multinational companies, governments, and academia, as well as advisors – the book provides in-depth analysis of the following aspects:
Over eighty examples and numerous references to case law are highlighted throughout the book.
How this will help you:
As a manual for understanding the distinct aspects of intangible assets that affect the application of transfer pricing rules, this book demonstrates in specific detail how careful attention to transfer pricing aspects of intangibles can avoid tax problems and forestall potential negative effects on a firm’s reputation. It is a one-stop solution for tax lawyers, tax authorities, corporate in-house counsel, academics, the business community, and advisory firms, empowering them to confidently tackle the transfer pricing issues of transactions involving intangibles.
Editors
Assistant Editor
Contributors
List of Abbreviations
List of Figures
List of Tables
Preface
CHAPTER 1
Introduction
Raffaele Petruzzi & Ruth Mirembe
CHAPTER 2
Patents
Richard Goh, Martin Lagarden, Philippe Paumier & Paul Sutton
CHAPTER 3
Know-How and Trade Secrets
Sven Kluge, Sven-Eric Bärsch & Xaver Ditz
CHAPTER 4
Trademarks, Tradenames, and Brands
Marc M. Levey, Joshua Wolkoff & Imke Gerdes
CHAPTER 5
Licences and Similar Limited Rights in Intangibles
Monika Bieri, Daniel Schönenberger & Caterina Colling-Russo
CHAPTER 6
Domain Names and Websites
Richard Schmidtke & Philipp Kunz-Kaltenhäuser
CHAPTER 7
Software and Technology
Lisa Bernhardt, Lasse Ottofrickenstein, Daniel Retzer & Alexander Totzek
CHAPTER 8
Franchise Agreements
Ágata Uceda, Valentin L. Krustev & Daniel Ruiz Ramírez
CHAPTER 9
Video and Audio-Visual Intangibles
Ritu Sharma, Melody Leung, Michael McDonald & Mary Frances Wines
Table of Cases
Index
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