Transfer Pricing and Intangibles

S. 145Valuation of intangibles – panel discussion

Below is a summary of the panel discussion on Session 4.The summary was composed by Sayee Prasanna, research and teaching associate at the Institute for Austrian and International Tax Law of WU (Vienna University of Economics and Business).

The panel discussion featured representatives from Business (hereinafter MNE), Advisory (hereinafter Advisor), and tax authorities (hereinafter Tax Authorities).

Introduction

For many MNEs, intangibles play a crucial role in the value creation process. Eighty percent or more of the value in Fortune 500 companies is set to be derived from intangibles that are developed or acquired. Therefore, understanding the role of intangibles in the Value Chain Analysis (VCA) and identifying the activities that have a significant influence on the value of the intangibles is essential for any valuation. Some of valuation exercises are done for accounting purposes. The “purchase price allocation” (PPA), however, does not entirely satisfy tax purposes. Some other valuation techniques are focused on the overall value created but not on how to make such values systematically relevant to transfer pricing.

Transfer pricing and ...