Transfer Pricing and Intangibles (eBook)

Current Developments, Relevant Issues and Possible Solutions

Michael Lang, Alfred Storck, Raffaele Petruzzi, Robert Risse (Herausgeber)

eBook Download: EPUB

2019 | 1. Auflage
100 Seiten
Linde Verlag Wien Gesellschaft m.b.H.
978-3-7094-1011-0 (ISBN)

Infos

Transfer pricing treatment of intangibles: Issues und developments

In recent decades, intangibles have become one of the most relevant success factors for Multinational Enterprises (MNEs). Along with the increasing importance of intangibles for economies, their tax treatment has also been under scrutiny which includes inter alia respective transfer pricing issues. MNEs are seeking for the best ways to optimize their business arrangements with the related intangibles while, at the same time, getting the most tax-efficient treatment. On the other hand, tax authorities have become increasingly concerned with the ease that intangibles can be used in aggressive planning. These concerns have been noticed and addressed by the Organization for Economic Cooperation and Development which presented its main findings with respect to transfer pricing aspects of intangibles in Action 8 of the BEPS Project in 2015 and in the 2017 OECD Transfer Pricing Guidelines.

This book is based on the outcomes of the presentations and discussions held during the WU Transfer Pricing Symposium, ‘Transfer Pricing and Intangibles: Current Developments, Relevant Issues and Possible Solutions’, that took place in October 2018 at the WU Vienna University of Economics and Business.

The publication discusses the most important issues and recent developments related to transfer pricing treatment of intangibles. Starting with the definition of intangibles, it further deals with topics such as appropriate attribution of intangible-related profits, structuring of intangibles in MNEs, and proper valuation of intangibles. The authors, apart from providing a theoretical background to the discussed issues, also present case studies that show how certain issues can be approached in practice. Every chapter ends with a summary of the discussions held during the panels of the Transfer Pricing Symposium in which representatives of tax administrations, multinationals, and tax advisories presented their opinions on the issues at stake.

Textauszug

XIList of authors

Editors

is Head of the Institute for Austrian and International Tax Law of WU (Vienna University of Economics and Business) and academic director of both the LLM Program in International Tax Law and the Doctoral Program in International Business Taxation (DIBT) of this university. He is president of the Austrian Branch of the International Fiscal Association (IFA) and has been a visiting professor at Georgetown University, New York University, Sorbonne, Bocconi, Peking University (PKU), University of New South Wales (Sydney), and at other universities.

is Co-Chairman of the Board of Directors of the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at Vienna University of Economics and Business (WU) and, since April 2009, a visiting professor at the same institute. The focus of his research and teaching activities is international business taxation and transfer pricing. From 2009 until January 2015, Alfred Storck was working as Honorary Professor at the University of St. Gallen, Switzerland. Before his activities at both universities, he held various executive positions (including head of Tax) in a large multinational company headquartered in Switzerland. Alfred Storck is acting as a co-editor of the journal “Transfer Pricing International” and as an arbitrator in transfer pricing disputes (Tax Treaty cases).

is the managing director of the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business) and an international tax advisor specializing in international corporate taxation and transfer pricing at L&P Global (Vienna) and at Ludovici Piccone & Partners (Milan). Since 2007, Raffaele has gained extensive experience in dealing with topics related to international corporate taxation and transfer pricing from both a practical perspective and from an academic perspective. He is a frequent speaker in international conferences and lecturer of numerous courses (in Europe, Asia, and Latin America), as well as author of many publications on international tax and transfer pricing topics. Finally, amongst others, Raffaele is a member of the United Nations Subcommittee on Transfer Pricing.

Global Head of Tax & Trade Department at Henkel AG & Co. KGaA, is Co-Chairman of the Board of Directors of the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at Vienna University of Economics and Business (WU) and, since August 2017, an honorary professor for tax compliance and applied tax planning for business taxation at the University of Leipzig. Robert has extensive experience as Global Head of Tax & Trade department at Henkel AG & Co. KGaA since 2000 and his leading tax positions at Deutsche Post AG, Mannesmann AG and Kaufhof Holding AG before 2000. Robert is a frequent speaker during scientific and professional events and his teaching activities focus mainly on international taxation, tax compliance and tax planning in practice.

Contributors

is an associate in the Transfer Pricing team of Flick Gocke Schaumburg in Bonn. She received her diploma in business administration from the Pforzheim University of Applied Sciences and the University of Cologne respectively and joint Flick Gocke Schaumburg right after the completion of her studies. Cornelia Andree advises multinational enterprises in transfer pricing, business restructurings and valuation issues and was appointed a certified tax advisor in 2018.

is a partner with EY, leading the EMEIA transfer pricing practice. He has studied accountancy at the Erasmus University in Rotterdam, postdoctoral IT-auditing at the Free University in Amsterdam and holds a master in fiscal economics from Tilburg University. Ronald has over 30 years of experience in taxation. Before joining EY, he has served the Dutch tax administration for 22 years, amongst others as the chair of the transfer pricing coordination group

received his law degree from the University of Warsaw, Poland in 2016 and a master’s degree in Italian law from the University of Catania, Italy in 2017. Currently, he is a research and teaching associate at the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business) and a team member of the WU Transfer Pricing Center. He cooperates scientifically in the area of tax law with Henkel AG & Co. KGaA. Karol is pursuing a doctoral degree in Business Law at the WU.

has been with Henkel group in Germany and the US for almost 25 years, holding various managerial positions in R&D and Finance/Controlling. Since 2008, he is Head of Global Transfer Pricing in Henkel’s Tax & Trade unit. His responsibilities comprise system development and digitalization in transfer pricing, international audit management and dispute resolution, documentation and related topics. He was awarded academic degrees from the Universities of Aachen, Bochum, Düsseldorf and Reading/Henley Business XIIISchool (UK). To date, he has (co-)authored several publications on different aspects of transfer pricing, including but not limited to intangibles and their valuation and documentation issues.

is a partner with the Transfer Pricing team of Flick Gocke Schaumburg in Hamburg. He has more than ten years of experience in transfer pricing, business restructurings, valuation issues and has particular experience in representing MNEs in transfer pricing tax audits and competent authority negotiations. He is also extensively involved in providing planning solutions to companies with cross-border transactions and has advised leading MNEs in various industries, including chemical, automotive, food and beverage, and energy. Dr. Liebchen is a guest lecturer at the Bundesfinanzakademie (German Federal Finance Academy). Daniel regularly gives speeches on transfer pricing, and is commentator of leading German transfer pricing and DTC commentaries and handbooks.

is the chair of NERA’s Global Transfer Pricing Practice. Emmanuel is an economist specializing in arm’s length transaction pricing, asset and business valuations, and intellectual property analyses. For close to 20 years, he has advised multinational companies and their legal advisors on defining and implementing their intra-group pricing policies, valuing assets including notably the pricing of complex transactions (intellectual property, financing, etc.). He has assisted them in the context of various re-structuring, pricing design and negotiations with tax authorities. He has provided economic analyses in the context of tax and intellectual property related litigations including the preparation of expert reports. He has also advised governments in relation to specific corporate income tax related cases. Prior to joining NERA, Emmanuel was an economist with Arthur Andersen in London and with the KPMG network in Paris. Emmanuel has a Ph.D in economics from the University of Delaware and a doctorate in economics from the University of Lyon. Emmanuel has been appointed as a member of the European Union Joint Transfer Pricing Forum. He is considered by Euromoney as one of the leading experts in Transfer Pricing.

is a senior economist in NERA’s Transfer Pricing, Intellectual Property, and Valuation Practices, based in Paris. Ralph’s work spans a wide range of industries for which he provides assistance in the context of advisory, compliance, dispute and litigation services. He has extensive experience designing and implementing complex systems and models driving the allocation of profits at multinational companies; as well as quantification of damages arising from commercial disputes. In addition to his Master’s degree in applied economics and international affairs from Paris Dauphine University and his executive education in advanced valuation from INSEAD Business School, Ralph studied micro-econometrics and competition economics at the Barcelona Graduate School of Economics.

received a Mag.iuris in Law from the University of Vienna and a BSc in Business Administration from WU (Vienna University of Economics and Business). He works as a teaching and research associate at the Institute for Austrian and International Tax Law, WU and is a team member of the WU Transfer Pricing Center.

is a Research and Teaching Associate at the Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business). She graduated from the Leiden University with an adv. LLM degree after which she worked at the cross-border tax department of Deloitte Malta. She is currently pursuing a PhD degree in Business Law from WU.

is a Teaching and Research Associate in the Transfer...

Produkt-Details

• Erscheint lt. Verlag: 11.4.2019
• Sprache: englisch
• Themenwelt: Recht / Steuern ► Steuern / Steuerrecht
• ISBN-10: 3-7094-1011-8 / 3709410118
• ISBN-13: 978-3-7094-1011-0 / 9783709410110