Intangibles in the world of transfer pricing : identifying - valuing - implementing / Björn Heidecke, Marc C. Hübscher, Richard Schmidtke, Martin Schmitt, editors.
Heidecke, Björn, editor.; Hübscher, Marc C., editor.; Schmidtke, Richard, editor.; Schmitt, Martin, editor.
2021
HD62.45
Available Online

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Title Intangibles in the world of transfer pricing : identifying - valuing - implementing / Björn Heidecke, Marc C. Hübscher, Richard Schmidtke, Martin Schmitt, editors.
ISBN 9783319733326 (electronic bk.)
331973332X (electronic bk.)
9783319733319
DOI https://doi.org/10.1007/978-3-319-73332-6
Published Cham : Springer, [2021]
Language English
Description 1 online resource (xii, 721 pages) : illustrations (some color)
Other Standard Identifiers 10.1007/978-3-319-73332-6 doi
Call Number HD62.45
Dewey Decimal Classification 658.8/16
Summary 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.
Bibliography, etc. Note Includes bibliographical references.
Access Note Access limited to authorized users.
Source of Description Online resource; title from PDF title page (SpringerLink, viewed March 11, 2021).
Added Author Heidecke, Björn, editor.
Hübscher, Marc C., editor.
Schmidtke, Richard, editor.
Schmitt, Martin, editor.
Available in Other Form Print version: 3319733311
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Record Appears in Online Resources > Ebooks
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Part I: Intangibles in the World of Transfer Pricing
Definition and identification of Intangibles
Allocation of IP for TP Purposes
Overview of IP Migration Models
Empirical Evidence on Various Models
What's Different?
Intangibles in the Mid-Market
Understanding the Reporting of Intangibles from a Business Perspective
Intangibles in Different Industries
The miracle of brand value creation: Where does the value come from?
Valuation: Understanding, assessing and documenting
Part II: Finding the Arm's Length Price for Intangibles
Structuring a license system
Contract Research and Development
Pool Concept Chapter II. 4
Transactional Profit Split Method
Part III: The Nighty Gritty Details on Valuation
Please mind the gap. Armþs length prices and fair market value
Market approach
Relief From Royalty
MEEM
Incremental cash flow method
Cost approach
Calculating Planning Data and Its Plausibility
Discount rates
Part IV: Country Perspective of Intangibles from a Transfer Pricing Perspective
Introduction
Austria
Belgium
Brazil
Canada
China
East Africa
France
Germany
Ghana
India
Italy
Mexico
Middle East
Nigeria
Poland
Russia
Spain
Sweden
United Kingdom
CJEU Court Cases
IP and Taxation
Part V: Implementing Intercompany Intangible Systems
Withholding Tax Aspects of License Models
A legal review of IP migrations
IP from an M & A Tax Perspective
Intellectual Property from a Customs Perspective.

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