Transactions involving intellectual property play an important role in
economic activity. This study not only highlights the problems encountered in
inter-affiliate transactions of intangible property, but also attempts to offer
solutions. It is useful to revenue authorities, multinational enterprise
executives, and tax practitioners.Transactions involving intellectual property play an increasingly
significant role in economic activity at every level from global to local, with
particular challenges for taxation and revenue authorities. Moreover, the
manifold complexities associated with identifying, valuing and transferring
intangibles make this an issue requiring a creative review of existing transfer
pricing methodologies and techniques. In this ground-breaking new study,
Michelle Markham offers an in-depth examination of attitudes at the forefront
of this rapidly evolving area of taxation law, focusing her work on a
comparative analysis of the US, OECD, and Australian perspectives on the
transfer pricing of intangible assets. "The Transfer Pricing of Intangibles"
not only highlights the current problems encountered in inter-affiliate
transactions of intangible property, but also attempts to offer a variety of
solutions to these problems.; Among the issues explored are the following: how the tax treatment of
intangibles in the context of transfer pricing has become a major international
tax concern; definitional issues which are vital to an understanding of
transfer pricing; application of the arm's length principle to intangible asset
transactions; determination of legal and economic ownership of group intangible
assets; intangible asset valuation and transfer; transfer pricing
methodologies; global formulary apportionment; transfer pricing documentation
requirements; penalties for non-compliance; resolution of transfer pricing
disputes; and advance pricing agreements. Revenue authorities, multinational
enterprise executives, and tax prac
