Transfer pricing of intangible property

Abstract

Transnational corporations (TNCs) regard transfer pricing as the most important tax issue confronting them in the immediate future. Coupled with the increase in the number and type of cross-border transfers of intangible property, concerns arise about the adequacy of current transfer pricing regulations, and the harmony, or lack thereof, of such regulations when a TNC must address both host- and home-country tax authorities. This study of TNCs domiciled in Canada, Germany, Japan, the United Kingdom, and the United States (US) reveals a similarity in corporation approaches to valuing intangible property that transcends national borders. This is in stark contrast to current practices regarding the transfer of tangible goods, which vary by country, rather than by industry or nature of the transferred good. However, in many cases, this agreement is reached because TNCs are using transfer pricing methods for intangible transfers that do not follow the Organization for Economic Cooperation and Development (OECD) and/or US Internal Revenue Service (IRS) guidelines.

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