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

‘Pro bono is a must’: Amory Heine on giving back

DLA Piper’s co-head of tax for the US and Latin America tells ITR about her fervent belief in equal access to the law, loving yoga, and paternal inspirations

July 15 2025

Direct Tax

‘Huge, complex’ pillar two system encroaches on sovereignty: EY tax leader

Tax expert Craig Hillier agrees with the comparison of pillar two to using a sledgehammer to crack a nut

Sam Sholli, July 14 2025

Direct Tax

London- HM Revenue and Customs building on Whitehall, UK Governm

HMRC believes US companies underpaid £8.8bn in tax: accountancy group

The amount is reported to be up 57% from the £5.6bn that the UK tax agency believes was underpaid in the previous year

Sam Sholli, July 14 2025

Indirect Tax

This week in tax: Donald Trump announces 50% tariff on Brazil

The US president also unveiled a new 50% levy on copper imports; in other news, a UK wealth tax proposal has been criticised by the Institute for Fiscal Studies

Sam Sholli, July 11 2025

Direct Tax

Exclusive: WTS Global CEO steps down

Wim Wuyts, who had been head of the specialist tax network since 2017, is moving on to a new role with WTS’s Belgian member firm

Tom Baker, July 10 2025

Transfer Pricing

When algorithms decide tax outcomes: embedding ethics in TP systems

MNEs are increasingly using algorithmic tools in TP. Sahasranshu Dash argues that data ethics should therefore plug directly into the TP design process

Sahasranshu Dash , July 10 2025

Transfer Pricing

Experts question whether UK TP proposal is ‘absolutely necessary’

The Institute of Chartered Accountants in England and Wales also queried whether HMRC resources could be better spent scrutinising larger entities

Sam Sholli, July 09 2025

Transfer Pricing

‘Coffee is the only constant’: Raphael Holzinger on the pressures of his practice

Grant Thornton’s Austria tax head likens his practice to an escape room, shares his football coaching ambitions, and explains why tax is cool

July 09 2025

Awards

ITR EMEA Tax Awards 2025: shortlist announced

ITR is delighted to reveal all the shortlisted nominees for the 2025 EMEA Tax Awards

John Harrison, July 08 2025

Awards

ITR APAC Tax Awards 2025: shortlist announced

ITR is delighted to reveal all the shortlisted nominees for the 2025 Asia-Pacific Tax Awards

John Harrison, July 08 2025