Taxpayers and practitioners should determine legal ownership in order to inventory the intangibles under analysis, and to provide a starting point in determining economic ownership/benefit.
Intellectual property, including patents, trademarks and license agreements, can be abundant for any single entity. Action 8 under BEPS plan of the Guidance on Transfer Pricing Aspects of Intangibles, acknowledges this fact by urging taxpayers and practitioners to first establish legal ownership of the intangibles. [1] Learn More.
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[1] See Action 8 ¶¶ 6.35
