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International Transfer Pricing: The Valuation of Intangible Assets by Monica Boos

International Transfer Pricing: The Valuation of Intangible Assets

By Monica Boos


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The valuation of intangible assets causes tax lawyers and economists a lot of trouble. And when assets cross borders, it gets worse. The (maybe not so-surprising) result is that a considerable number of multinational enterprises use a transfer pricing method to value intangible assets that seems not to comply with regulations of either home or host tax authorities. Although this is a matter of the utmost practical concern, the persistence¿even growth¿of the problem clearly raises theoretical issues. This volume considers the valuation of intangible assets from both perspectives, theory and practice, building its practical recommendations on a sound theoretical analysis of the appropriateness of transfer pricing rules for intangible assets as well as on the adequacy of transfer pricing standards and methods for the economic reality of multinational enterprises.

With expert insight into the difficulties inherent in the current regulatory approaches to valuing intangible asset transfers within multinational enterprise networks, the author combines three strands of current concerns, namely:

  • research into the theory of the multinational enterprise, intangible asset valuation, and international transfer pricing;
  • comparison of transfer pricing policies when intangibles are involved; and
  • the ongoing policy discussions on the subject among international organizations, tax authorities, and taxpayers.

    The price-setting behavior of multinational enterprises; why intangibles are valuable; the elusiveness of economic fairness standards when every case is different¿these are among the thought-provoking issues raised in this book. As both a thorough summary of the major ideas and key public policies in its specialized field and a clarifying presentation of recommendations as well as topics and issues for further research, International Transfer Pricing ¿ The Valuation of Intangible Assets will greatly benefit international taxation professionals, whether in business, government, or academia.

  • Publish Date 07/31/2003
    Publish Frequency As Needed
    Product Line Kluwer Law International
    ISBN 9789041199256
    SKU 10058074-0001
    Table of Contents
      Contents: Figures. Tables. Exhibits. Abbreviations. 1. Rationale for International Transfer Pricing of Intangibles. 2. Intangibles and MNEs: Understanding Production, Use and Investment. 3. Valuing Intangible Transfers¿Theoretical Approach. 4. Valuing Intangible Transfers¿Practical Approach. 5. Valuing Intangible Transfers¿Transfer Pricing Approach. 6. Problems, Policy Issues and Options for Reforms. 7. Whither International Transfer Pricing of Intangibles? References.