Mukesh Butani of Taxand India explains why the OECD’s revised discussion draft on intangibles is a step in the right direction
The OECD’s revised discussion draft on intangibles (RDD) seeks to provide guidance on action point 8 of the BEPS action plan concerning the transfer pricing of intangibles.
The RDD highlights that return on intangibles should be attributed to the entity which performs important functions provides all assets and assumes key risks and costs related to the development enhancement maintenance and protection of intangibles. The RDD explicitly mentions that mere legal ownership of an intangible shall not entitle the legal owner of any return establishing precedence of ‘economic ownership’ over ‘legal ownership’.
The RDD further mentions that key functions in relation to an intangible may include design and control of research and marketing programmes management and control of budgets control over strategic decisions regarding intangible...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.
Home >Articles > OECD’s revised discussion draft on intangibles
OECD’s revised discussion draft on intangibles
Mukesh Butani of Taxand India explains why the OECD’s revised discussion draft on intangibles is a step in the right direction
The OECD’s revised discussion draft on intangibles (RDD) seeks to provide guidance on action point 8 of the BEPS action plan concerning the transfer pricing of intangibles.
The RDD highlights that return on intangibles should be attributed to the entity which performs important functions provides all assets and assumes key risks and costs related to the development enhancement maintenance and protection of intangibles. The RDD explicitly mentions that mere legal ownership of an intangible shall not entitle the legal owner of any return establishing precedence of ‘economic ownership’ over ‘legal ownership’.
The RDD further mentions that key functions in relation to an intangible may include design and control of research and marketing programmes management and control of budgets control over strategic decisions regarding intangible...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
