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Table of Contents
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.
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.