India - Intellectual Property Migration: Analysis from an Indian Transfer Pricing Perspective
- S.K. Bilaney
- International Transfer Pricing Journal, 2012 (Volume 19), No 1
- 29 December 2011
The author considers several issues central to the migration of intellectual property to an associated enterprise in a low-tax or tax-privileged jurisdiction, including valuation methods and the taxation of any resulting gains. Challenges to such migration under the Direct Taxes Code Bill 2010 are also addressed.