Features

The past three years have seen significant changes to the Colombian tax framework, generally constituting a convergence with international tax concepts. Ximena Zuluaga and Luis Orlando Sánchez, of EY, explore the changes introduced by the 2012 tax reform and associated regulations released at the end of 2013 and assess the scope for further reform measures.

Increased globalisation has resulted in significant pressure on US multinationals to take a more global view not only of their operations but also of the manner in which they hold, manage, and develop intangible assets. As a result of these drivers, transferring intangible property (IP) out of the US group to a controlled foreign corporation (CFC) may make sense, explain David Cordova, Gretchen Sierra and Douglas Cowan.

John Henshall and Achim Roeder explain why it would be unwise to underestimate the impact of business restructuring. The impact extends to the discussion on the revision of chapter VI of the OECD transfer pricing guidelines on intangibles.

Marco Fiaccadori, Arindam Mitra, and Robert Plunkett explain how to reconcile the licensor-licensee profit split approach with the income approach.