While transfer pricing has risen to the forefront of international tax issues in the last two decades, this has coincided with a concomitant increase in the importance of intangibles in the global economy. The so-called 'new economy' of the 21st century has seen business enterprises,...

In the 21st century, the number one international tax issue of interest to multinational enterprises (MNEs) is undoubtedly transfer pricing. The reason for this is that as global trade increases, so too does the uncertainty of the tax treatment of inter-affiliate transactions across national...

International transfer pricing, essentially the pricing of intercompany transactions between international associated enterprises and the determination of the amount of income to be allocated to each party, is one of the most important international tax issues facing a multinational enterprise...