Category: Transfer Pricing & BEPS

Global regulations are changing, and the way Transfer Pricing professionals go about their benchmarking analyses is changing right alongside. ktMINE is dedicated to keeping our products, our customers, and the general public updated on Transfer Pricing topics. From Base Erosion Profit Shifting (BEPS), to current events, visit the ktMINE Transfer Pricing & BEPS articles for education and news.

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The OECD Discussion Draft on Intangibles and the Myth of Unavailable Comparables

Authored by David R. Jarczyk, and Jeffrey Cozzo, this article argues that the Organization for Economic Cooperation and Development’s revised discussion draft on intangibles lacks guidance on the available market evidence to answer the central question of an arm’s length analysis: How would independent parties act given the tested transactions’ facts and circumstances? Versions Published In: October,

IP facts you can’t afford to miss…but you probably do

Authored by David R. Jarczyk, this article outlines the pitfalls of relying solely on unredacted license agreements when performing transfer pricing analyses and the competitive advantage afforded those who have access to the entire universe of license agreements. Versions Published In: March 12, 2013 WWTPR Journal – Second Edition November, 2012 Bloomberg BNA Transfer Pricing International Journal

Comment on Discussion Draft on the Transfer Pricing Aspects of Intangibles

Authored by David R. Jarczyk, this article provides a response to the OECD’s request for comment on the transfer pricing aspect of intangibles. The comments within highlight common misconceptions related to the application of the CUT/CUP method, along with recommendations for the expansion of the comparability analysis section. Versions Published In: September 30, 2012 OECD.org Read Full Article