Transfer Pricing and Intangibles
1. Aufl. 2019
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S. 36Below is a summary of the panel discussion on Session 1.The summary was composed by Mag. Karol Dziwiński and Mag. Mario Riedl, Research and Teaching Associates at the Institute of Austrian and International Taxation at WU.
The panel discussion featured representatives from Business (hereinafter MNE), Advisory (hereinafter Advisor), and tax authorities (hereinafter Tax Authorities).
1. Panel discussion
This question was aiming to deal with the following issues:
Is the condition of a compensation in a 3rd party context appropriate to limit the scope in practice?
What is the difference between intangibles and the comparability factor?
Does the irrelevance of the TP definition for other tax purposes create “tensions”?
Is the condition of a compensation in a 3rd party context appropriate for limiting the scope in practice?
Tax authorities: For me, the answer is obvious. What should be our concern is whether the compensation for a transaction is arm’s length, whereby if the transaction is subject to such compensation depends on the relevant legislation. Coming to the definition of intangibles, it talks about the compensation to be be paid between 3rd parties, and it also discusses the ...