This paper is about the tangibles and the intangibles of the controlled transactions. Therefore we have an analysis of the tangibles which are the property with the services, and the intangibles which are the assets of the controlled transactions in the transfer pricing procedure. Therefrom,...

Numerous empirical studies have analysed the influence of corporate taxation on the location of intangible assets within a company group. However, the previous literature has rather focused on studying the impact of taxation on patent location choices assuming that these assets represent the...

The study analyses the difference in profitability between Multinational affiliates and domestic firms regarding the financial sector and some European Countries, in the period 2003 -2011. Tax Heaven Countries are excluded.We segmented two different periods: the first period (2003-2007) is about...

Large multinational companies are regularly suspected of using transfer pricing of intangibles to shift profits from high- to low-tax jurisdictions. We study the optimal transfer prices while endogenizing the location choice of intangibles and considering spillovers. In line with the initial...

Despite OECD efforts to combat profit shifting, recent literature shows that firms with higher ratios of intangible assets have increased income shifting activities. Intellectual property is used more than other forms of capital by MNCs to shift income from high to low tax jurisdictions....

The article examines the problem of contributed zero-basis intangibles in light of the IRS’s inadvertent disclosure of a transaction structured by Bristol-Myers Squibb to shift billions of dollars of built-in gain to a related foreign partner

Based on French firm-level data over around 15 years we evaluate the contribution of the micro-level profit shifting –through tax haven foreign direct investments to the aggregate productivity slowdown measured in France. We show that firm measured productivity in France declines over the...

In this paper is analyzed the case of the coordination between tangibles and intangibles. Moreover, scrutinized the issue of the arm's length principle with one new view, which is the fixed length principle. This established principle shows a way to face the tax losses from a global economic...