Intra-Group IP Transfers Following International M&A Transactions – Challenges and Best Practice from a (Swiss) Transfer Pricing Perspective
Journal
International; Switzerland
International Transfer Pricing Journal 2023 (Volume 30), No. 3
The post-M&A transfer of intellectual property raises a number of challenging questions from a transfer pricing perspective. By means of a case study, the author illustrates the use of international valuation standards in the context of intellectual property and transfer pricing (fair value versus arm’s length principle) as well as the treatment of pricing premiums and milestone payments.