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Getting to Grips with Intangibles & Transfer Pricing

Richard Fletcher Senior Tax Director with Baker & McKenzie London Office examines some of the key aspects of transfer pricing in relation to intangibles
Since the introduction of ICTA 1988 Schedule 28AA introducing the transfer pricing rules in UK legislation in their current form there has been continuous development in the nature of controversies arising in application of that legislation. Perhaps one of the most marked areas where the level of sophisticated argument has developed significantly is that relating to the impact of intangibles upon transfer pricing in multinational enterprises (MNEs).
At a very basic level this development may be attributed to the fact that by definition intangibles tend to be very valuable to a MNE and therefore cash and profit flows associated...

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