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This will interest every multinational company that own, license or use intangibles! |
| OECD Update on Intangibles |
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7-9 November 2011 - As part of the project to revise Chapter VI on Intangible Property for the OECD Transfer Pricing Guidelines, the OECD met with the business community to hear 18 presentations on the: 1. Definition of intangibles; 2. Goodwill and Going Concern; 3. Brands and Brand Value; 4. Ownership Issues; and, 5. Synergies.
Mr. Chris Lennon, the Chair of the Business and Industry Advisory Committee (BIAC) for the OECD, said the overriding objective of the business community for this project is to achieve certainty and to achieve a set of rules that will help eliminate double taxation.
Ms. Michelle Levac, the Chair of the OECD committee for this project, recognized the difficulty of providing clear guidance, consultation with the business community has been helpful, and confirmed they are on track for issuing the revisions in draft by December 2013.
Click here for more details including copies of the presentations.
This is the fifth in the ongoing series of Transfer Pricing Alerts on this topic. Learn more by reading past issues. Click here. |
| IRS Update on Intangibles |
26 October 2011 - the U.S. Chair of the House Ways and Means Committee released a draft tax reform plan that includes a provision to tax excess income (over 150% of the costs) from transfers of "covered intangibles" to low-tax jurisdictions where the effective rate of income tax imposed by the foreign country is 10% or less.
The draft defines "covered intangibles" to be any intangible property "(A) which is sold, leased, licensed, or otherwise transferred (directly or indirectly) to such controlled foreign corporation from a United States related person, or (B) with respect to which such controlled foreign corporation and one or more related persons has (directly or indirectly) entered into any shared risk or development agreement (including any cost sharing agreement). There are special rules for research and development expenses.
Click here for more details including a copy of the Discussion Draft. |
| OECD Update on Chapter IV |
8 July 2011 - The OECD published the 25 responses that it received for Chapter IV on the Administrative Approaches to Avoiding and Resolving Transfer Pricing Disputes. Click here for more details.
10 June 2011 - The OECD released a document containing a "Multi-country Analysis of Existing Transfer Pricing Simplification Measures" on which comments were also invited. Click here for more details. |
| Transfer Pricing Services |
MDW Consulting Inc. is the Canadian member of the Altus Alliance, an international association of transfer pricing professionals. Please contact us if you have questions about these or other transfer pricing issues that concern you.
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