Valuation of intangibles for direct tax and customs purposes : is convergence the way ahead?

This article explores the feasibility of interaction and potential convergence of valuation methods of intangibles for direct tax and customs purposes. As far as economic considerations are concerned, this article provides an overview of the main characteristics of intangible property, followed by an analysis of the methods applicable to intangibles for both transfer pricing and customs duties that highlights the major divergences in the current valuation processes of the tax and customs authorities, respectively. Remarks and suggestions are provided as to the opportunity for convergence in the valuation of intangibles for transfer pricing and customs purposes.