International - Transfer Pricing Aspects of Intangibles: At the Crossroads between Legal, Valuation and Transfer Pricing Issues
- I. Verlinden; Y. Mondelaers
- International Transfer Pricing Journal, 2010 (Volume 17), No 1
- 23 December 2009
The OECD Global Forum on Tax Treaties and Transfer Pricing in a Changing World, held in Paris on 21-22 September 2009, included a session on the treaty and transfer pricing aspects of the characterization of intangibles. In addition to considering the highlights of this session, the authors analyse the underpinnings of the issue, including the determination of whether a definition of intangibles is at all needed for transfer pricing purposes.