Transfer Of Intangible Property: Transfer Pricing Regulations Under Irs And Oecd

Multinational companies (MNCs) have now adopted new global business models in place of traditional models. One common objective of strategic tax planning for intangible assets is to reduce their worldwide long-term tax liabilities. When transferring intangible assets across the borders to reduce taxes, MNCs frequently assign income to special purpose subsidiaries in tax-haven countries. To provide strategic and updated implementation of section 1.482-4(f) (3) of IRS Tax Code relating to the transfer of intangibles and allocation of income attributed to intangible property, the IRS and Treasury department want to modify and supplement the said section for proper harmonization and coordination rules relating to transfer of intangibles.

The following questions have been addressed in this article:

What is "intangible property?"
What was the need to supplement and amend section 1.482-4(f)(3) relating to the allocation of income attributable to intangible property.


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