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 firm has hired a team of private client lawyers from Withers to launch in New York and Connecticut, though ITR analysis suggests it faces stiff competition
The ability of tax authorities to receive and analyse data is becoming ‘quite advanced’, warns Stuart Lang, head of EY’s compliance co-sourcing solution
The Court of Appeal ruling clarifies that treaty benefits are not abusive where transactions are commercially driven, providing greater certainty on “main purpose” anti-avoidance tests
Despite the Netherlands featuring an unusual concentration of World Tax-ranked technology-led providers, sources believe there’s a long way to go to challenge the established players
The repeal of Libya’s statute of limitations and tougher enforcement leave taxpayers navigating a high-stakes choice between conciliation and litigation
All the tax partners elevated across the UK, US and Singapore were private client specialists, continuing a market trend of intense investment and competition