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This book provides the most important issues and recent developments related to transfer pricing treatment of intangibles. Based on the outcomes of the WU Transfer Pricing Symposium it contains the opinions of representatives of tax administrations, multinationals and tax advisories.

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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.

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Lang, Michael
Professor am Institut für Österreichisches und Internationales Steuerrecht an der WU Wien.

Storck, Alfred
Visiting professor at the Institute for Austrian and International Tax Law at WU Wien and former honorary professor for company taxation and managerial finance at the Institute of Accounting, Controlling and Auditing (ACA) at the University of St. Gallen/Switzerland. 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).

Petruzzi, Raffaele
Dr. Raffaele Petruzzi, LL.M. is 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).

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