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Books > Law > Laws of other jurisdictions & general law > Financial, taxation, commercial, industrial law > Financial law > Taxation law
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The Transfer Pricing of Intangibles (Hardcover)
Loot Price: R7,426
Discovery Miles 74 260
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The Transfer Pricing of Intangibles (Hardcover)
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Transactions involving intellectual property play an increasingly
significant role in economic activity at every level from global to
local, with particular challenges for taxation and revenue
authorities. Moreover, the manifold complexities associated with
identifying, valuing and transferring intangibles make this an
issue requiring a creative review of existing transfer pricing
methodologies and techniques. 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 intangibles 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 formulary apportionment;
transfer pricing documentation requirements; penalties for
non-compliance; resolution of transfer pricing disputes; and
advance pricing agreements. Revenue authorities, multinational
enterprise executives, and tax practitioners around the world will
greatly appreciate the recommendations and solutions proposed in
this knowledgeable and thoughtful book. Its acute sense of the
opportunities and pitfalls of an ever-more-complex area of economic
activity place it in a category of its own, of inestimable benefit
to interested parties.
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