Business Services Industry
Transfer pricing for intangible development: cost-sharing alternatives.
Australasian Business Intelligence, January, 2006
Byline: Clarke Norton and Paul Burns
Jan 22, 2006 (International Tax Review - ABIX via COMTEX) -- The US Internal Revenue Service (IRS) has moved to stamp out certain cost-sharing practices. Multinational corporations have
discovered that it can be advantageous in terms of tax management to locate ownership of intellectual property in certain nations.
Some have developed a habit of creating intangible holding companies for this purpose, but the IRS has proposed legislative
reform that would prevent such practices. There are several alternatives to cost- sharing that businesses can use to achieve
the same effect. Real options methods are...
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