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Transfer Pricing and Intangibles

Transfer Pricing and Intangibles

Author: Michael Lang; Raffaele Petruzzi
Publisher: Kluwer Law International
ISBN: 9789403506692

Published In: November 2025
Format: Hardback
Jurisdiction: Netherlands ? Disclaimer:
Countri(es) stated herein are used as reference only

List Price: $243.15

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Description
Contents
Author

Details

About this book:

Transfer Pricing and Intangibles is a unique book with a comprehensive approach to the practical application of transfer pricing rules to intangibles that opens a clear path to an effective and compliant application of the core principles, taking into consideration recent developments and providing valuable insights about industries that rely on specific intangibles. More and more business models worldwide have come to rely intrinsically on intangible assets. Because transactions involving intangibles are particularly susceptible to the complexity surrounding transfer pricing rules, these transactions must be conducted following a proper transfer pricing analysis.

What’s in this book:

With contributions from stakeholders who interact daily with transactions involving intangibles – representatives from multinational companies, governments, and academia, as well as advisors – the book provides in-depth analysis of the following aspects:

introduction to transfer pricing of intangibles;
transfer pricing of patents;
transfer pricing of know-how and trade secrets;
transfer pricing of trademarks, trade names and brands;
transfer pricing of licences and similar limited rights in intangibles;
transfer pricing of domain names and websites;
transfer pricing of software and technology;
transfer pricing of franchise agreements;
transfer pricing of video and audio-visual materials.

Over eighty examples and numerous references to case law are highlighted throughout the book.

How this will help you:

As a manual for understanding the distinct aspects of intangible assets that affect the application of transfer pricing rules, this book demonstrates in specific detail how careful attention to transfer pricing aspects of intangibles can avoid tax problems and forestall potential negative effects on a firm’s reputation. It is a one-stop solution for tax lawyers, tax authorities, corporate in-house counsel, academics, the business community, and advisory firms, empowering them to confidently tackle the transfer pricing issues of transactions involving intangibles.

Editors

Contributors

List of Abbreviations

List of Figures

List of Tables

Preface

CHAPTER 1

Transfer Pricing and Intangibles

CHAPTER 2

Transfer Pricing Aspects of Patents

CHAPTER 3

Transfer Pricing Aspects of Know-How and Trade Secrets

CHAPTER 4

Trademarks, Tradenames, and Brands

CHAPTER 5

Transfer Pricing Aspects of Licences and Similar Limited Rights in Intangibles

CHAPTER 6

Transfer Pricing Aspects of Domain Names and Websites

CHAPTER 7

Transfer Pricing Aspects of Software and Technology

CHAPTER 8

Transfer Pricing Aspects of Franchise Agreements

CHAPTER 9

Video and Audio-Visual Intangibles

Index

Raffaele Petruzzi

PETRUZZI Advisory; WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU
Founder and CEO; Managing Director

Dr. Raffaele Petruzzi, LL.M. is an independent advisor on international tax and transfer pricing matters, the Founder and CEO of PETRUZZI Advisory, and the