While transfer pricing has risen to the forefront of international tax issues in the last two decades, this has coincided with a concomitant increase in the importance of intangibles in the global economy. The so-called 'new economy' of the 21st century has seen business enterprises,...

Transactions involving intellectual property play an increasingly significant role in economic activity at every level from global to local, with particular challenges for taxation and revenue authorities. Moreover, the manifold complexities associated with identifying, valuing and transferring...

The requirement in many OECD countries for "contemporaneous documentation" of a taxpayer's transfer pricing methodologies in order to avoid exposure to substantial penalties has led more taxpayers to consider entering into an Advance Pricing Agreement (APA). To these taxpayers, APAs represent an...

International transfer pricing, essentially the pricing of intercompany transactions between international associated enterprises and the determination of the amount of income to be allocated to each party, is one of the most important international tax issues facing a multinational enterprise...