International - Valuation of Intangibles under Income-Based Methods – Part I
- J. Wittendorff
- International Transfer Pricing Journal, 2010 (Volume 17), No 5
- 27 August 2010
This article examines the application of income-based methods to determine the arm’s length price of the transfer of an intangible, and discusses alternative non-arm’s length taxation approaches relating to intangibles. The domestic transfer pricing regimes of the United States, Germany and Denmark form the basis for the discussion of the use of income-based methods.