Intangible assets are becoming increasingly important as value
drivers for multinational companies. It is a strategic question how
to allocate intangibles within the multinational corporation. It
needs to be defined by whom and under which conditions they can be
utilized. Typical IP migration models such as licensing, joint
development and transferring are becoming a focal point within tax
audits across the globe. Hence,defining an intangibles system that
fulfils the tax requirements is of utmost strategic importance for
multinational corporations. A central question is how to value
intangibles in line with the arm's length principle as is required
internationally for transfer pricing purposes. Edited by leading
transfer pricing and valuation experts in Europe, this
comprehensive book offers practitioners an effective road map for
identifying, valuing and implementing intangibles for transfer
pricing purposes under consideration of both the OECD and local
perspectives. It is therefore a must-have book for transfer pricing
and valuation practitioners on all levels of experience. The book
starts with an introduction to the role of intangibles in the world
of transfer pricing including typical intangibles migration models.
It describes common intangible assets across all types of
industries, including e.g. automotive, consumer goods and
software.Using several numerical examples, the book then covers
state-of-the-art valuation methods including how to apply these
methods in practice in a way consistent with the OECD Transfer
Pricing Guidelines. The different country chapters written by local
experts provide country-specific guidance on the legal framework
concerning intangible assets from a transfer pricing and valuation
perspective. Finally, the book covers practical advice on the
implementation of an intangible assets system. This book offers
invaluable guidance to practitioners seeking tools to apply the
arm's length principle in the world of intangibles.
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