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International - The BEPS Action 8 Final Report: Comments from Economists

D.R. Wright; H.A. Keates; J. Lewis; L. Auten
International Transfer Pricing Journal, 2016 (Volume 23), No 2
26 February 2016
This article comments on the OECD Action 8 Final Report relating to transfers of intangibles within a multinational enterprise. Specifically, it contains comments about the MNEs that are most likely to be affected and about the incentive structure created by the Final Report. In addition, this article discusses the practical application of many of the requirements contained in the Final Report, such as the definition and identification of intangible assets (including examples of such assets), issues relating to functional analysis, and comments on transfer pricing methods and valuation techniques (including comments on the application of the income method).
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