Intangible transactions are one of the most challenging topics in the transfer pricing area, not only from a theoretical perspective but also because of the increasing number and size of the disputes regarding their recognition and valuation. Oliver Wehnert and Jakob Frotscher of Ernst & Young provide an outline of the major challenges in the identification and valuation of intangible assets
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
The OECD’s project was up for debate as Matt Williams spoke to ITR following BDO’s tax strategist survey, which uncovered increased complexity and costs among multinationals
Jean-Michel Henry and Mona El-Begawi of Deloitte Luxembourg examine the complexities created by timing differences in Luxembourg, EU, and OECD tax regimes
Samuel Fernandes de Almeida of MFA Legal & Tech assesses whether Portugal’s 7.5% surcharge on non-residents aligns with the EU’s free movement of capital principle and passes the proportionality test
Senior McCarthy Tétrault tax practitioners highlight significant updates and implications for multinationals as Canada’s transfer pricing rules become more closely aligned with OECD guidance