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| Content Provider | OECD iLibrary |
|---|---|
| Organization | OECD |
| Abstract | This chapter discusses special considerations that arise in seeking to establish whether the conditions made or imposed in transactions between associated enterprises involving intangible property reflect arm's length dealings. Particular attention to intangible property transactions is appropriate because the transactions are often difficult to evaluate for tax purposes. The chapter discusses the application of appropriate methods under the arm's length principle for establishing transfer pricing for transactions involving intangible property used in commercial activities, including marketing activities. It also discusses specific difficulties that arise when the enterprises conducting marketing activities are not the legal owners of marketing intangibles such as trademarks and trade names. Cost contribution arrangements among associated enterprises for research and development expenditures that may result in intangible property will be discussed in Chapter VIII. |
| Page Count | 14 |
| Starting Page | 151 |
| Ending Page | 164 |
| Language | English |
| Publisher | OECD Publishing |
| Publisher Date | 2009-08-18 |
| Access Restriction | Open |
| Subject Keyword | Finance and Investment Taxation Industry and Services Trade |
| Content Type | Text |
| Resource Type | Chapter |
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