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Intellectual Property

  • Editorial

  • Willingness to pay: how the microeconomic toolbox applies to brand valuation

    There is no silver bullet for capturing brand value, believe Alexander Voegele and Richard Sedlmayr of NERA Economic Consulting

  • Contribution analyses under the profit split method

    If applied based on sound economic principles, contribution analyses are powerful tools to address the bulk of most complex transfer pricing issues, explain Sébastien Gonnet & Pim Fris of NERA Economic Consulting

  • How franchising arrangements could apply in transfer pricing

    Franchising may be an appropriate framework for analysing intra-group transactions, including potentially in industries where third-party franchising is generally not observed, believe Emmanuel Llinares of NERA Economic Consulting in Paris and Nihan Mert-Beydilli of NERA Economic Consulting in Chicago

  • Taxing intangible property

    Japanese regulators are grappling with transfer pricing rules for intangible property. Karl Gruendel of Shin Nihon Ernst & Young, explains what the outcome will be

  • Modelling risk

    Rebel Curd, Robin Hart, and Catie Magelssen of the Ballentine Barbera Group, a CRA International company, explore the potential for risk in an investment model recently published by the IRS

  • Transfer pricing for intangibles under HMRC's new approach

    Outside expertise will allow the UK tax authorities to attack transactions they view as risky with a whole new level of sophistication, says Ted Keen of the Ballentine Barbera Group, a CRA International company. UK taxpayers who have not yet done so should revisit their transfer pricing documentation, particularly where transfers of valuable intangible property are concerned

  • Valuing know-how and knowledge through bottom-up approaches

    Top-down and bottom-up represent the two types of valuation logic that exist for the quantification of arm's-length royalties for know-how and knowledge in intercompany transactions, explain Alexander Vögele and Wolf Witt of NERA Economic Consulting

International Correspondents