The tax treatment of intangibles in the context of transfer pricing

Research output: Contribution to journalArticleResearchpeer-review

Abstract

This paper highlights the increasing importance of intangibles in the international dealings of multinational enterprises. Focussing on fiscal regulations in the United States and in OECD member countries, particulary Australia, it critically reviews the arm's length principle and related issues in their application to intangible property. It examines the complexities associated with the various methodologies that have been developed for determining arm's length consideration for transfers of intangibles, and puts forward some suggestions for developing an appropriate typology.
Original languageEnglish
Pages (from-to)1-32
Number of pages34
JournalRevenue Law Journal
Volume9
Issue number1
Publication statusPublished - 1999

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Transfer pricing
Tax
Intangibles
Methodology
Multinational enterprises
Fiscal

Cite this

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title = "The tax treatment of intangibles in the context of transfer pricing",
abstract = "This paper highlights the increasing importance of intangibles in the international dealings of multinational enterprises. Focussing on fiscal regulations in the United States and in OECD member countries, particulary Australia, it critically reviews the arm's length principle and related issues in their application to intangible property. It examines the complexities associated with the various methodologies that have been developed for determining arm's length consideration for transfers of intangibles, and puts forward some suggestions for developing an appropriate typology.",
author = "Michelle Wills",
year = "1999",
language = "English",
volume = "9",
pages = "1--32",
journal = "Revenue Law Journal",
issn = "1034-7747",
publisher = "Bond University Press",
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}

The tax treatment of intangibles in the context of transfer pricing. / Wills, Michelle.

In: Revenue Law Journal, Vol. 9, No. 1, 1999, p. 1-32.

Research output: Contribution to journalArticleResearchpeer-review

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AB - This paper highlights the increasing importance of intangibles in the international dealings of multinational enterprises. Focussing on fiscal regulations in the United States and in OECD member countries, particulary Australia, it critically reviews the arm's length principle and related issues in their application to intangible property. It examines the complexities associated with the various methodologies that have been developed for determining arm's length consideration for transfers of intangibles, and puts forward some suggestions for developing an appropriate typology.

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