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The case highlights a new challenge of attributing intangible-related profits, namely identifying the owners of intangibles.

TP in China: SAT tapping into the tax big data paradise

Transfer pricing continues to be one of the Chinese State Administration of Taxation’s key focus areas, write Cheng Chi, Rafael Triginelli Miraglia and Choon Beng Teoh of KPMG. New policies and methodologies are being examined post-BEPS to strengthen the SAT’s monitoring of MNEs’ TP.

August 30 2018

McDermott Will & Emery hires three new state and local tax lawyers

McDermott Will & Emery has responded to the increasingly complex US tax environment by hiring three state and local tax lawyers.

Joe Stanley-Smith, August 29 2018

Coca-Cola faces big US tax bill if Medtronic loses dispute

Coca-Cola’s profit split method may result in the soft drinks giant having to pay a $3.3 billion tax bill if the US Tax Court decides to reverse its earlier decision on the Medtronic case.

Josh White, August 29 2018

Asia Pacific – a harmonious interplay between transfer pricing and customs valuation?

The rise of integrated supply chains, complex organisational structures and inter-company transactions, means the harmonious interplay between customs valuation and transfer pricing has never been more important, writes Leonie Ferretter of KPMG. However, across the Asia Pacific region, we continue to see disparity in how TP is treated from a customs perspective.

August 28 2018

Moving away from traditional methods: Lessons from recent Japanese TP cases

The Tokyo District Court recently issued two judgments regarding transfer pricing (TP) cases, both in relation to the treatment of intangibles. These decisions provide insights into how the Japanese tax authorities will evaluate intangibles when dealing with TP issues in audits going forward, explain Yutaka Kitamura and Jun Sawada of Deloitte.

August 28 2018

Revisiting intangibles in the financial services sector

There is a lot of discussion about the future of the financial services sector, write Ralf Heussner and Enrique Marchesi-Herce of Deloitte. New technologies and automation, a changing regulatory landscape, and the entry of new market players are reshaping the industry. On top of this, the industry is undergoing further consolidation while having to respond to shifting customer demands and new distribution models.

August 28 2018

Acquisitions – are you ready for transfer pricing complexity?

We have seen a strong start to 2018 in terms of M&A activity, write Jon Vine and Greg Smith of Deloitte. Mergers and acquisitions invariably involve a range of complex tax issues. While these continue to include matters such as acquisition structuring, financing and structurally integrating the acquired business, the complexity and range of transfer pricing (TP) issues which arise in the M&A context should not be underestimated.

August 28 2018

Editorial

Welcome to International Tax Review's guide to intangible assets, published in association with Deloitte. In today's digital revolution, intangible assets are as central to the business function as steam-powered machines were during Industrial Revolution.

August 28 2018

Embedded IP

Andre Schaffers and Filip Vanluydt of Deloitte explain the concept of embedded intellectual property (IP), providing detailed guidelines for readers on how to identify and quantify it.

August 28 2018

The hypothetical arm’s-length test: Germany’s way of calculating the ALP for IP

The German approach to determining the arm’s-length price for intangibles/intellectual property (IP) is based on the relevant German tax code and related administrative guidance, explain Richard Schmidtke, Bjorn Heidecke and Oskar Glaser of Deloitte. If other methods are used to determine the arm’s-length price for IP, this may result in non-compliance in Germany.

August 28 2018

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