- Valuation of Intellectual Property: In the context of globalization and technological advancement, intellectual property has emerged as a crucial asset for capital groups, leading to increased licensing transactions between related parties, which are closely monitored by tax authorities.
- Importance of Documentation: Experts from MDDP emphasize that precise documentation, including well-defined licensing agreements, is essential for securing licensing transactions. These agreements should outline the license’s subject matter, the impact on income generation, and profit distribution based on actual functions performed.
- Comprehensive Transfer Pricing Strategy: To protect against potential disputes, businesses should maintain thorough transfer pricing documentation, including function, asset, and risk analyses, alongside reliable comparative studies to confirm market value. Consistency with the group’s transfer pricing policy is crucial to minimize contestation risk and ensure compliance during tax audits.
Source MDDP
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