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International - A New Era in Determining Arm’s Length Compensation for Intangibles? A Comparative Overview of Existing and Possible Future Transfer Pricing Principles

Country:
International
Author:
L. Helderman; E. Sporken; R. Okten; M. Kanter
Issue:
International Transfer Pricing Journal, 2013 (Volume 20), No 6
Published:
12 September 2013
The authors compare current transfer pricing principles and possible future OECD-based transfer pricing principles as set out in the 2012 OECD Discussion Draft on intangibles; consider the positions taken by the US and Dutch tax authorities as regards arm’s length consideration related to intangibles; and analyse court cases from various jurisdictions in order to illustrate third-party behaviour in the area of intangibles.
 
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