Titlebook: Intangibles in the World of Transfer Pricing; Identifying - Valuin Björn Heidecke,Marc C. Hübscher,Martin Schmitt Book 2021 Springer Nature

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Valuation: Understanding, Assessing, and Documentingary unit). The question arises about what a good valuation or measuring process is. This chapter outlines the concept of narratives and numbers. It shows that a good valuation requires both an accurate numerical process, i.e., the calculation part, as well as a convincing narrative that puts the cal

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Contract Research and Developmentact R&D setups, a popular method for aligning a transfer pricing structure with intercompany R&D outsourcing. This chapter describes the core features of contract R&D structures and establishes that in a typical setup the principal entity should be in control of all value-adding strategic functions

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Transactional Profit Split Method value creation of a group’s entities to estimate the respective profit allocation. In this context, the Transactional Profit Split Method (“TPSM”), one of the transfer pricing methods available in the OECD Transfer Pricing Guidelines, plays an increasingly important role in discussions about arm’s

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Overview of IP Migration Modelstion models seen in practice. Further, the history and recent developments on an international level with regard to the competition between tax systems for IP will be outlined as well as typical limitations and drawbacks.