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.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
MNEs now face a shift from modelling to execution as the side‑by‑side deal forces tax teams to upgrade systems, harmonise data, and prevent costly pillar two mismatches
Almost three-quarters of surveyed tax professionals are concerned about inaccurate AI outputs; in other news, Dentons hired a partner from CMS to lead its Belgian tax team
Brazil’s shift to a nationwide consumption tax is more than conceptual; it fundamentally transforms municipal revenue, enforcement, and administrative disputes