Martin Zetter reviews the latest transfer pricing developments from around the world
The US 2015 Budget proposed by the White House to Congress contains transfer pricing measures pre-empting the OECD work on the transfer of intangible assets.
Intangibles would be more widely defined to include goodwill going concern value and a workforce in place. Where a number of intangibles are transferred together the IRS might value them separately or in combination depending on what they believe gives a more reliable result. Furthermore where the IRS considers that transactions other than those actually carried out would have been available and they represent a realistic commercial alternative these alternative transactions may be taken into account when the IRS values the intangibles.
Why it matters
Defining intangibles to include items...
