Tax planning with intangibles has become one of the most popular and most vividly debated topics in international taxation. We incorporate various intellectual property (IP) tax planning models into forward-looking measures of effective tax rates, namely the disposal of intangibles to low-tax...

This study creates and analyzes a model in which the income from intellectual property (IP) owned by a domestic parent and foreign subsidiary must be shared between the domestic and foreign countries for tax purposes. The model focuses on the effects of the commensurate with income standard,...

We study the relation between patent concentration and tax-motivated income shifting. Using affiliate-level data for European multinational corporations (MNCs) and employing the relative share of patents held by an MNC as a measure for patent concentration, we predict and find that tax-motivated...

Economic theory implies that research and development (R&D) efforts increase firm productivity and ultimately profits. In particular, R&D expenses lead to the development of intellectual property (IP) and IP commands a return that increases overall profits of the firm. This hypothesis is...

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...

One of the main problems in evaluating intangibles is that the existing Arm Length Standard (ALS) methods are based on evaluation of future value of intangibles in their very early development stage before there is sufficient information on its value. When all the information and control is in...

Intellectual property owner/operators often retain forensic accountants, financial advisors, industry consultants, licensing specialists, economists, and other professionals (collectively referred to herein as “analysts”) to perform valuation, damages, or transfer price analyses related to...

Intellectual property owners and operators often need to know a value opinion, a damages measurement, or a transfer price determination regarding their intellectual property. Owners and operators may need to know these conclusions for transaction, taxation, licensing, financing, financial...

Die Festlegung von Verrechnungspreisen zwischen international verbundenen Unternehmen gewinnt zunehmend an Bedeutung. So befasst sich nahezu jede Betriebsprüfung bei Unternehmen mit Geschäftsbeziehungen zu verbundenen Unternehmen im Ausland mit der Angemessenheit der gewählten...