The IRS's position should not be considered to conflict with the arm's length principle. The OECD countries can always hold this view against the U.S., by stating that highly valuable marketing intangibles were created in the hands of OECD distributors. Now that it has been determined that U.S....

This article reviews the recent landmark transfer-pricing case law in Canada. It suggests that the Canadian courts may have given birth to a sixth comparability factor for the application of the arm's-length principle that contravenes the intent of section 247 of the Income Tax Act. This new...

The paperwork aims at comparing interpretation of the definition of intangibles and ownership determination in order to apply transfer pricing laws and rules in the US, Russia, and particularly the OECD transfer pricing approach.Transfer pricing of intangibles is a hot issue among OECD members....