The adequate pricing of intellectual property (“IP”) for tax reporting is a largely unsettled issue. Transactional profit-based methods are on the rise although only rated as “methods of last resort” by the OECD. This paper focuses on regulated profit splitting and compares this transfer...

The adequate pricing of intellectual property (“IP”) for tax reporting is a largely unsettled issue. Transactional profit-based methods are on the rise although only rated as “methods of last resort” by the OECD. This paper focuses on regulated profit splitting and compares this transfer...

The OECD seeks to align transfer pricing and profit taxation with value creation but fails to provide a clear definition. This paper argues that value creation requires international cooperation and that the profit tax base should therefore be allocated according to standards commonly considered...

Inter-country equity in the taxation of IP is a contentious issue. With its BEPS initiative, the OECD aims at taxing in accordance with value creation even though there are admitted difficulties in determining the actual place of value creation. The European Commission promotes the introduction...

The OECD seeks to align transfer pricing and profit taxation with value creation but fails to provide a clear definition. This paper argues that value creation requires international cooperation and that the profit tax base should therefore be allocated according to standards commonly considered...

The adequate pricing of intellectual property ("IP") for tax reporting is a largely unsettled issue. Transactional profit-based methods are on the rise although only rated as "methods of last resort" by the OECD. This paper focuses on regulated profit splitting and compares this transfer pricing...

Inter-country equity in the taxation of IP is a contentious issue. With its BEPS initiative, the OECD aims at taxing in accordance with value creation even though there are admitted difficulties in determining the actual place of value creation. The European Commission promotes the introduction...