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Transfer Pricing: Entitlement to Intangible Related Returns

Stojanova, Aleksandra LU (2013) HARN60 20131
Department of Business Law
Abstract
The entitlement to the income arising from the development and use or transfer of the intangible property within the MNE group members has been contentious issues for transfer pricing purposes. This paper aims to discuss and analyse the concept of entitlement to intangible related returns, considering the application of the arm’s length principle with regard to allocation of the benefits as provided within the Article 9 of the OECD MTC. Following the importance of the future enhancement of the harmonization of the legislation of the countries with the OECD principles, the OECD documents are considered, especially the Chapters I-III, VI, VIII and IX of the OECD TPG, as well as the Discussion Draft with regard to Chapter VI will be observed.
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author
Stojanova, Aleksandra LU
supervisor
organization
course
HARN60 20131
year
type
H1 - Master's Degree (One Year)
subject
keywords
Transfer Pricing, Intangibles, Intangible related returns
language
English
id
3801045
date added to LUP
2014-01-27 10:19:52
date last changed
2014-01-27 10:19:52
@misc{3801045,
  abstract     = {The entitlement to the income arising from the development and use or transfer of the intangible property within the MNE group members has been contentious issues for transfer pricing purposes. This paper aims to discuss and analyse the concept of entitlement to intangible related returns, considering the application of the arm’s length principle with regard to allocation of the benefits as provided within the Article 9 of the OECD MTC. Following the importance of the future enhancement of the harmonization of the legislation of the countries with the OECD principles, the OECD documents are considered, especially the Chapters I-III, VI, VIII and IX of the OECD TPG, as well as the Discussion Draft with regard to Chapter VI will be observed.},
  author       = {Stojanova, Aleksandra},
  keyword      = {Transfer Pricing,Intangibles,Intangible related returns},
  language     = {eng},
  note         = {Student Paper},
  title        = {Transfer Pricing: Entitlement to Intangible Related Returns},
  year         = {2013},
}