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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

Just over two weeks before #americastaxawards2015. Remind yourself of the nominees here http://t.co/QL3XigqXYg http://t.co/ST2LnOdkEa

Sep 1 2015 04:57 ·  reply ·  retweet ·  favourite
International Tax Review Profile

Selection will start soon for #globaltax50 for 2015. Who should be on the list? Read last year's list for ideas http://t.co/qY4Astan9A

Sep 1 2015 04:54 ·  reply ·  retweet ·  favourite
International Tax Review Profile

#maninthenews Najib Razak was in our #globaltax50 in 2014. Read his write-up here http://t.co/IqCKa6Fc4P http://t.co/8Phn1gLoxg

Aug 31 2015 01:28 ·  reply ·  retweet ·  favourite
International Tax Review Profile

#ff @garrigues_es @ey_mena @AriasMunoz @Withers_PR @womenintax

Aug 28 2015 10:22 ·  reply ·  retweet ·  favourite
International Tax Review Profile

#China #Taiwan agree #tax treaty http://t.co/YWLTE1ULFN

Aug 28 2015 03:27 ·  reply ·  retweet ·  favourite
International Correspondents

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