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Intangibles published in association with Deloitte (November 2012)

Main

Editorial

Introduction

Business restructuring: Exit charges for restructurings in Europe

BMO: Business model optimisation – pitfalls to avoid

Discussion draft: OECD’s discussion draft on intangibles: A positive step forward

IP transfers: Tax and accounting considerations

BMO evolution: The evolution of business model optimisation

IP valuation: IP valuation, payment form, and discount rates

Start-up IP: Intellectual property planning for start-ups

Licensor-licensee profit split and the income approach

Features Articles

Editorial

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  • A mere change in profitability will not, of itself, justify an exit charge
    Sponsored by Deloitte UK
    Business restructuring: Exit charges for restructurings in Europe
    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.
    December 17, 2012
  • Parties entering into license agreements are ultimately concerned with their own expected monetary gains from such ventures
    Sponsored by Deloitte US
    Licensor-licensee profit split and the income approach
    Marco Fiaccadori, Arindam Mitra, and Robert Plunkett explain how to reconcile the licensor-licensee profit split approach with the income approach.
    December 17, 2012
  • Proceeds from the sale of IP may be ordinary income or capital gain
    Sponsored by Deloitte US
    IP transfers: Tax and accounting considerations
    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.
    December 17, 2012