Intellectual property (IP) is the major value driver in the global value chains of multinationals. Correspondingly, given its impact on profit allocations between group affiliates, it is also the most controversial transfer pricing issue both in tax legislation and tax audit practice. Yves Herve and Susann van der Ham of PwC focus on German particularities that arose out of new tax legislation from four years ago.
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
China and a clutch of EU nations have voiced dissent after Estonia shot down the US side-by-side deal; in other news, HMRC has awarded companies contracts to help close the tax gap