Tax treatment of services : does the value of patents and technical know-how prevail over the value of marketing efforts?

Discusses international tax consequences of the relative value of intangibles and marketing efforts, taking into account their relationship with the tax treatment of services under Section 482 of the US Internal Revenue Code. In the author's view, each unit of a multinational group should, as a matter of principle, be considered a separate taxpayer. Next, he presents his arguments why the difficulties in determining intercompany prices should not open the door for the application of the profit split method.