Copying and distributing are prohibited without permission of the publisher

Intangibles published in association with Deloitte

  • Editorial

  • Introduction

  • Business restructuring: Exit charges for restructurings in Europe

    John Henshall and Achim Roeder explain why it would be unwise to underestimate the impact of business restructuring. The impact extends to the discussion on the revision of chapter VI of the OECD transfer pricing guidelines on intangibles.

  • BMO: Business model optimisation – pitfalls to avoid

    In this economic environment, companies around the world are looking to optimise the way they conduct business and enhance their bottom lines. Andrew Newman and Brian Pinto explain that companies are also interested in aligning their tax planning with their business strategy to further enhance their financial efficiencies, allowing the business to make better after-tax investment decisions.

  • Discussion draft: OECD’s discussion draft on intangibles: A positive step forward

    Shanto Ghosh, John Wells, and Todd Wolosoff discuss the recent stages in the OECD’s project into the transfer pricing aspects of intangibles and comment on the inconsistencies in the draft and what these could mean for taxpayers.

  • IP transfers: Transfers of IP – tax and accounting considerations

    Increased globalisation has resulted in significant pressure on US multinationals to take a more global view not only of their operations but also of the manner in which they hold, manage, and develop intangible assets. As a result of these drivers, transferring intangible property (IP) out of the US group to a controlled foreign corporation (CFC) may make sense, explain David Cordova, Gretchen Sierra and Douglas Cowan.

  • BMO evolution: The evolution of business model optimisation

    Tom Driscoll, Kathrine Kimball, Bill Lam, Dan Munger and Keith Reams explain the evolution of business model optimisation in transfer pricing and how this can relate to the economic environment.

  • IP valuation: IP valuation, payment form, and discount rates

    The valuation of intellectual property (IP) for transfer pricing purposes has recently received a lot of attention from the US government. Philippe Penelle and Lawrence Shanda take taxpayers through the specifics of IP valuation, payment forms and discount rates, in light of the IRS’s new focus on migrated IP.

  • Start-up IP: Intellectual property planning for start-ups

    The unrelenting pursuit of profit by enterprises is an exalted virtue of modern capitalism. Most start-ups operate in countries where corporate taxes can take up a significant portion of their ultimate profits or valuations. Aydin Hayri and James Gannon explain why a start-up ignores corporate taxation at its own peril.

  • Licensor-licensee profit split and the income approach

    Marco Fiaccadori, Arindam Mitra, and Robert Plunkett explain how to reconcile the licensor-licensee profit split approach with the income approach.


International Tax Review Profile

RT @EY_Tax: Australian Labor Party to introduce Private Member's Bill to accelerate #Disclosure of >$100m corporate tax entities' tax paid …

Oct 30 2014 03:51 ·  reply ·  retweet ·  favourite
International Tax Review Profile

RT @CommonsPAC: Interesting point by @Shell Alan McLean in a breakout-business supports transparency for a purpose, not just for the sake o…

Oct 30 2014 03:49 ·  reply ·  retweet ·  favourite
International Tax Review Profile

#PACtaxconf keynote speaker #JustinKing ex-CEO @sainsburys legitimate for business should take part in #tax debate http://t.co/WiRLBhdnnX

Oct 30 2014 02:38 ·  reply ·  retweet ·  favourite
International Tax Review Profile

RT @IrishTimesBiz: German commissioner floats proposal for EU levy on Google http://t.co/lbpe5K4ILu

Oct 30 2014 01:18 ·  reply ·  retweet ·  favourite
International Tax Review Profile

RT @financialtrivia: 5 states do not have any statewide sales tax: AK, DE, MT, NH and OR (Rockefeller Institute of Government) #tax

Oct 30 2014 12:57 ·  reply ·  retweet ·  favourite
International Correspondents

After the Irish budget, what would make you more likely to put more substance into Ireland?