Transfer Pricing and Intangibles in the Context of Business Restructurings


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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Rubem Mauro
KLA-Koury Lopes Advogados

I am a lawyer with a strong background in brazilian and international tax practice. I have been... View Profile »

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