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Valuation of Transactions Related to Intangibles from Transfer Pricing and VAT Perspective

Berdzuli, Davit LU (2020) HARN60 20201
Department of Business Law
Abstract
What are the intangibles and how transactions related to them should be evaluated from a direct
and indirect tax perspective is one of the crucial questions of the modern tax systems and
business operators. OECD provides a combination of methods and rules that can be applied for
direct tax purposes. However, answers to these questions are not easy to find in the European
Value Added Tax (VAT) system.
The thesis addresses the legal challenges inherent in the application of tax rules to intangibles,
both from transfer pricing (TP) and VAT perspective. It provides an analysis of the basic features
of TP and European VAT, as well as how the intangibles concept is understood in their context.
The study also seeks to examine the... (More)
What are the intangibles and how transactions related to them should be evaluated from a direct
and indirect tax perspective is one of the crucial questions of the modern tax systems and
business operators. OECD provides a combination of methods and rules that can be applied for
direct tax purposes. However, answers to these questions are not easy to find in the European
Value Added Tax (VAT) system.
The thesis addresses the legal challenges inherent in the application of tax rules to intangibles,
both from transfer pricing (TP) and VAT perspective. It provides an analysis of the basic features
of TP and European VAT, as well as how the intangibles concept is understood in their context.
The study also seeks to examine the challenges that acquire in the process of applying evaluation
techniques accepted by VAT Directive and the possibility of using TP methods for determining
the taxable amount for VAT purposes. The analysis demonstrates that in the light of the legal
character of VAT there is not much room for harmonization. (Less)
Please use this url to cite or link to this publication:
author
Berdzuli, Davit LU
supervisor
organization
course
HARN60 20201
year
type
H1 - Master's Degree (One Year)
subject
language
English
id
9011692
date added to LUP
2020-06-12 10:58:56
date last changed
2020-06-12 10:58:56
@misc{9011692,
  abstract     = {{What are the intangibles and how transactions related to them should be evaluated from a direct
and indirect tax perspective is one of the crucial questions of the modern tax systems and
business operators. OECD provides a combination of methods and rules that can be applied for
direct tax purposes. However, answers to these questions are not easy to find in the European
Value Added Tax (VAT) system.
The thesis addresses the legal challenges inherent in the application of tax rules to intangibles,
both from transfer pricing (TP) and VAT perspective. It provides an analysis of the basic features
of TP and European VAT, as well as how the intangibles concept is understood in their context.
The study also seeks to examine the challenges that acquire in the process of applying evaluation
techniques accepted by VAT Directive and the possibility of using TP methods for determining
the taxable amount for VAT purposes. The analysis demonstrates that in the light of the legal
character of VAT there is not much room for harmonization.}},
  author       = {{Berdzuli, Davit}},
  language     = {{eng}},
  note         = {{Student Paper}},
  title        = {{Valuation of Transactions Related to Intangibles from Transfer Pricing and VAT Perspective}},
  year         = {{2020}},
}