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 OECD had previously missed a June 30 deadline to agree an MLC on amount A; in other news, UK corporation tax bills surged to a record high last year