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The Transfer Pricing of Intangibles Michelle Markham

The Transfer Pricing of Intangibles

Michelle Markham

Published July 1st 2005
ISBN : 9789041123688
Hardcover
335 pages
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 About the Book 

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 perspectivesMoreIn 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 arms 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.