Title
Transfer pricing of intangible property: Harmony and discord across five countries
Document Type
Article
Publication Date
9-2001
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.
Language
English
DOI
https://doi.org/10.1016/S0020-7063(01)00108-X
Recommended Citation
Borkowski, Susan C., "Transfer pricing of intangible property: Harmony and discord across five countries" (2001). Department of Accounting Faculty Work. 11.
https://digitalcommons.lasalle.edu/accounting_faculty/11
Comments
This article is the authors' final published version in The International Journal of Accounting, Volume 36, Issue 3, September 2001, Pages 349-374.
The published version is available at https://doi.org/10.1016/S0020-7063(01)00108-X. Copyright © Elsevier Inc.