Transfer Pricing for Intangibles in Light of Recent OECD Proposals
Sep 3, 2013
Tuesday, September 24, 2013, 12:30–1:30 pm
In this Webinar, Mr. Steven Hannes, a partner at McDermott Will & Emery, and Dr. George Korenko, a partner at Edgeworth Economics, will discuss transfer pricing for intangibles in light of the OECD’s recently issued Action Plan on Base Erosion and Profit Shifting and Revised Discussion Draft on Transfer Pricing Aspects of Intangibles.
In particular, the Discussion Draft states that legal ownership of intangibles or funding of their development does not by itself entitle a group member to any returns on those intangibles. Rather, taxpayers should, in addition to having legal ownership, use functions performed, assets used, and risks assumed to determine which group members are entitled to the returns from intangibles. Under the Discussion Draft, it is critical to “control” functions of significance outsourced to affiliates.
Mr. Hannes and Dr. Korenko will focus on the legal and economic issues associated with having group members participate directly in and/or oversee and control the development of intangibles.
Register for the free Webinar here: https://www4.gotomeeting.com/register/791115527.