Transfer pricing is widely acknowledged as the top international tax issue for multinational companies with related-party (or controlled) transactions. Frequently these transactions involve intangibles, and the transfer prices assigned to such intangibles transactions are among the most heavily scrutinized by tax authorities across the world. Join Kash Mansori and Guy Sanschagrin for an overview of the regulatory environment governing the transfer pricing of intangibles, and a comprehensive discussion on the valuation methods used by transfer pricing specialists, enforcement and controversy related to intangibles transfer pricing, and specific case studies. Gain an understanding of how both multinationals and tax authorities approach the transfer pricing of intangibles and the specific methods used to determine the valuation of intangibles for transfer pricing purposes.
Program Agenda
Definitions and Regulations
Intangibles Income Streams:
Scenarios and Specific Considerations
Transfer Pricing Methods
Case Study #1
Intangibles Asset Sales:
Scenarios and Specific Considerations
Methods of Valuation
Case Study #2
Enforcement and Controversy
Learning Objectives
How transfer pricing regulations and the arm’s length standard govern the valuation of intangibles for transfer pricing purposes
How to apply transfer pricing methods to determine the value of assets or income streams related to intangibles transactions
How tax authorities enforce and scrutinize the transfer prices that multinationals assign to controlled transactions involving intangibles
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