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Indicia of economic ownership of intangible property

The question of who owns intangible property has been at the forefront of many transfer pricing controversies. Aydin Hayri and Darcy Alamuddin present a framework for identifying the economic or beneficial owner of intangible property, which from a transfer pricing perspective can be just as important as legal ownership, and illustrates its use in the case study of a hypothetical life sciences company.

January 23 2014

Transfer pricing of intangibles: Media and entertainment

The US television production industry, just one of the segments within the media and entertainment space, reported total revenue of $35.6 billion and a profit of $6.1 billion, or 17% of revenue in 2012. Mark Nehoray, Kristine Riisberg, and Anna Soubbotina take an industry focused look at dealing with intangibles.

January 23 2014

The venture valuation model and cost sharing CWI rules

Marco Fiaccadori, Arin Mitra, and Philippe Penelle provide a practical analysis of the venture valuation model and cost sharing rules.

January 23 2014

Acquisition premiums and cost sharing analysis

In the world of mergers and acquisitions, it is fairly common to observe a difference between the actual price paid in acquiring a target company and the preacquisition fair value of the company, the acquisition premium. Keith Reams, Lawrence Shanda, Joe Tobin, and Wen-Fang Liu analyse the concept.

January 23 2014

Abbott uses Davos speech to outline Australia’s G20 aims

Tony Abbott, Prime Minister of Australia, gave an address today at the 44th Annual Meeting of the World Economic Forum (WEF) in Davos, Switzerland, setting out Australia’s priorities for its G20 presidency.

Matthew Gilleard, January 23 2014

Location-specific advantages: India and China

The issue of location-specific advantages (LSAs) has received significant attention recently, with India and China formally stating their positions in the UN Transfer Pricing Manual issued October 2012, and in subsequent discussions. Shanto Ghosh, Wei Shu, and Rahul Tomar explore the concept.

January 23 2014

Hollande to cut French business taxes – but there’s a catch

President Francois Hollande has proposed a €30 billion ($40 billion) easing of the French business tax burden, but only if companies show a commitment to invest and hire.

Matthew Gilleard, January 23 2014

The evolving procurement model

Michael Gilson, John Wells, Andrew Feinberg, and Andrew Newman explain why harnessing a company’s procurement function is important in tax planning.

January 23 2014

International tax issues and cloud computing

Cloud computing is not only revolutionising the way companies conduct business, it is also raising questions as to how cloud-based businesses should be taxed. Ron Saake and Mandana Malone provide clarity on the issue.

January 23 2014

Introduction

Dear readers,

January 23 2014

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