Intangibles are more important than ever before. They are an essential value driver for MNEs. The OECD, EU and UN have been implementing guidance related to transfer pricing and intangibles. The OECD will present the blueprints for Pillar I and Pillar II in October 2020. Legislators in many jurisdictions have implemented the DEMPE approach in their transfer pricing guidance. Further, the EU General Court decided on the tax rulings in the Apple case and the European Commission decided to widen the scope of its investigation into the Netherlands’ tax treatment of an IKEA subsidiary. At the same time, we see an increase in tax audits and litigation related to transfer pricing and intangibles. Often these cases relate to royalty rates, cost sharing or intangibles being transferred within the group. Last but not least, due to COVID-19, many MNEs will need to restructure their businesses. Since, these restructurings often concern intangibles, these will trigger the attention of the tax authorities of the countries involved.
This webinar provides an overview of the latest developments on transfer pricing and intangibles. The presenters will share their expertise and give us insight into the key risks related to aforementioned developments and how organizations may deal with them.