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Brand value: drawing the link between value creation and economic benefit

The complex distinction between legal ownership and economic ownership of intangible assets means multinationals must take proactive measures to avoid transfer pricing controversy, say Christine Ramsay, Jordi Morera, and Marguerite Mei of Deloitte

Christine Ramsay, September 25 2024

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Intangibles transfer pricing, transaction delineation, and corporate dynamism

With the pricing of intangibles laced with difficulty, Ishan Maini, Eric Linge, and Richard Schmidtke of Deloitte draw on two cases in Germany and Israel revolving around differing interpretations concerning the delineation of transactions

Ishan Maini, September 25 2024

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Recharacterisation in transfer pricing audits: focus on Poland and Germany

Mariusz Każuch, Inka Traeger, and Conrad Marburg of Deloitte consider tax authorities' recharacterisation of intercompany transactions through drawing on recent practice in Poland and Germany, and suggest proactive measures global businesses can take

Mariusz Każuch, September 25 2024

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Determining an arm’s-length range: countries’ experiences across Asia-Pacific

Aaron Wang, Carlo L Navarro, and Rebecca Cook of Deloitte explain several Asia-Pacific jurisdictions’ differing approaches towards the construction of an arm’s-length range amid the shifting contours of the region’s transfer pricing landscape

Aaron Xin Peng Wang, September 25 2024

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Penalties in transfer pricing controversy: always show your working

Multinationals attempting to avoid and mitigate penalties potentially arising from transfer pricing controversy could take a tip from standard exam advice. Eddie Morris and Aydin Hayri of Deloitte explain the importance of recording actions

Eddie Morris, September 25 2024

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