Trends In Transfer Pricing Of R&D And IP Activities
Overview
Trends in transfer pricing of R&D and IP activities
In the wake of BEPS reforms and the global pandemic, corporate reorganizations, whether driven by commercial needs or efforts to reduce controversy risks, often involve the restructuring of intangible assets and related R&D functions. These changes must be carefully assessed through the lens of transfer pricing rules outlined in the OECD Guidelines, along with the specific interpretations adopted by individual jurisdictions.
At the same time, there has been a noticeable rise in tax audits and litigation concerning transfer pricing and intangibles. Common areas of dispute include royalty rates, cost-sharing arrangements, and the transfer of intangibles within multinational groups. This webinar explores the key pressure points that frequently lead to such disputes, strategies for managing these risks, and the potential implications of the OECD’s two-pillar framework on the future structuring of intangibles and R&D activities.
What you will earn from this webinar
- Pinpoint the sections of the OECD Transfer Pricing Guidelines on intangibles that are most likely to trigger cross-border tax disputes.
- Examine the main challenges multinational enterprises face when determining arm’s length pricing for R&D activities and transactions involving the use or transfer of intangible assets.
- Review recent policy developments and case law to understand how legislative changes and judicial decisions are shaping transfer pricing practices related to intangibles.
Webinar information
| Type | Webinar |
| Language | English |
| Level | Intermediate |
| Cost | EUR 115 |
| Live date | 30 January 2024 |
Topics Covered:
Block 1: Explore current trends in how multinational enterprises structure intangible assets and R&D functions, focusing on evolving global tax practices.
Block 2: Understand how the OECD Transfer Pricing Guidelines apply to these structures, identifying common areas of dispute and offering practical strategies for managing controversy.
Block 3: Review recent case law to uncover key lessons and assess the potential impact on multinational groups’ transfer pricing and structuring decisions.
Prerequisites:
This webinar is designed for professionals with a solid foundation in international tax. It is best suited for participants who have between three to five years of experience and are already familiar with the core principles of international tax law.
Who should participate:
This session is tailored for in-house tax professionals and advisors who want to deepen their understanding of transfer pricing considerations in the structuring of intangibles and R&D activities within multinational groups. It also addresses the needs of legal professionals who are evaluating compliance risks under Chapter VI of the OECD Transfer Pricing Guidelines and seeking effective ways to manage potential disputes. Additionally, the session is relevant for government officials involved in auditing and enforcing transfer pricing rules in intragroup transactions related to intangibles and R&D functions.
Do you need to do advanced preparation:
No advance preparation is needed. Participants are expected to be familiar with the key concepts of international tax law.