Hard-to-Value Intangibles: How Hard Can It Be?

Journal
Konings, B.; Morren, D.
International
International Transfer Pricing Journal 2021 (Volume 28), No. 1
PriceUSD 45

Hard-to-value intangibles are in the spotlight for reasons of the upcoming DAC6 reporting obligations, although the fundamental question is how to account for this notion when transferring IP within an MNE? According to the authors’ experiences, this is still quite unclear to both taxpayers and authorities, so they come up with an alternative approach.