How franchising arrangements could apply in transfer pricing

December 01 2007

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

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login

Topics

Intellectual Property (November 2007)

more across site & shared bottom lb ros

More from across our site

Direct Tax

Baker McKenzie picks up former US Treasury deputy Scott Levine

Levine, who served under the Joe Biden administration, led the US’s negotiations on the OECD’s two-pillar solution

Tom Baker, April 30 2025

Direct Tax

Legal Benchmarking Group acquired by Triple Private Equity

The deal to acquire ITR's parent company is expected to complete by the end of May 2025

Tom Baker, April 29 2025

Direct Tax

Meat multinational JBS accused of dodging $442m in taxes

JBS, the biggest meat company in the world, allegedly used Luxembourgian ‘mailbox companies’ to avoid taxes between 2019 and 2022

Tom Baker, April 28 2025

Direct Tax

Australian tax adviser imprisoned for operating while unregistered

Despite the conviction of Jessa Dabalos, the Tax Practitioners’ Board’s investigative work continues with five outstanding PwC scandal probes

Tom Ravlic, April 28 2025

Direct Tax

Female hand with megaphone on white background

Why in-house tax teams should do their own PR

Heads of tax need to push their teams forward as strategic business advisers to add value across their organisations, says Sandy Markwick

Sandy Markwick, April 25 2025

Direct Tax

This week in tax: Elon Musk and Treasury secretary clash over IRS leadership

Scott Bessent reportedly felt undermined by Musk naming Gary Shapley as acting IRS commissioner; in other news, Baker Tilly will combine with a top 15 US firm

Tom Baker, April 25 2025

Transfer Pricing

India’s record APAs a win for government efficiency: experts

The promise of nine years’ tax certainty and a ‘rational and pragmatic’ government process makes APAs a no-brainer, Indian tax advisers tell ITR

Tom Baker, April 24 2025

Transfer Pricing

Fixing Italy’s approach to taxing digital business

Despite garnering significant revenues from multinationals, Italy’s digital services tax presents pressing double taxation issues, say Stefano Simontacchi and Francesco Saverio Scandone of BonelliErede

Stefano Simontacchi , April 23 2025

Direct Tax

Copy of What Corporates Want 2025 (1).png

Asian clients unimpressed with firms’ team depth, exclusive data reveals

ITR’s research shows that in-house tax counsel in Asia also feel underserved by their advisers’ international networks

Tom Baker, April 22 2025

Direct Tax

World Tax and ITR Awards: how to write a winning submission

World Tax global head of research Jon Moore tells ITR how his team spots standout submissions, and gives early statistical insights into this year’s entries

Tom Baker, April 21 2025