Transfer pricing of intangible assets in the US, the OECD and Australia: Are profit-split methodologies the way forward?
In the 21st century, the number one international tax issue of interest to multinational enterprises (MNEs) is undoubtedly transfer pricing.¹ The reason for this is that as global trade increases, so too does the uncertainty of the tax treatment of inter-affiliate transactions across national boundaries and the spectre of double taxation. The Australian Deputy Commissioner of Taxation has outlined the concept of transfer pricing as follows: 'Broadly, transfer pricing relates to the setting of prices by multinationals for the goods and services that they supply to related parties. It also covers the structuring of transactions and financial relationships, and how innovation happens and is rewarded .'²
¹ ² See notes in article.
© Copyright The University of Western Sydney and Michelle Markham, 2004
Michelle Markham. "Transfer pricing of intangible assets in the US, the OECD and Australia: Are profit-split methodologies the way forward?" University of Western Sydney law review 8 (2004): 55-78.