Transfer Pricing and Intangibles in the Context of Business Restructurings

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The recent developments in the field of transfer pricing and business restructurings need to be analyzed more carefully and this research is mainly to identify transfer pricing issues arising for MNE Groups whenever they decide to restructure their functions by transferring intangible property.

Also, this paper will identify what is an intangible property, who is considered to be the owner of the intangible, when a intangible is deemed to be transferred and how to achieve the arm's length price for the controlled transaction. Moreover, this research will analyze a few issues pointed out by the OECD in the Discussion Draft regarding transfer pricing aspects of business restructurings.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Rubem Mauro, KLA-Koury Lopes Advogados | Attorney Advertising

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