Definition of intangibles

OECD Issues Draft Guidelines Pertaining to Intangibles  December 14, 2009 – 12:43 pm
Table I.Definition of

The OECD has released a discussion draft clarifying issues specific to intangibles involving multinational enterprises after 18 months since initiating the project in late 2010. The OECD issued the interim draft after consulting with the business community, in order to invite public comment from all stakeholders involved. The discussion draft was prepared by OECD Working Party No. 6 and contains proposed revisions to Chapter VI of the OECD Transfer Pricing Guidelines and to the corresponding illustrative examples that appear in the Annex to Chapter VI.

The overarching goal of this discussion draft is to address major issues not covered in the previous guidelines, in addition to soliciting input from stakeholders. The interim draft is divided into four sections:
1. Definition of intangibles
2. Identification of parties entitled to intangible-related returns
3. Transactions involving the use or transfer of intangibles
4. Determining arm’s length conditions or prices in transactions involving intangibles

Written comments on the discussion draft are requested by September 14, 2012.

Related Links:

(a) OECD
(b) PWC
(c) International tax review

Source: TP analytics

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In so concluding, the court enumerated some of the concrete tangible benefits that flow from civil marriage, including, but not limited to, rights in property, probate, tax, and evidence law that are conferred on married couples. Id. at 322-325. The court also noted that "intangible benefits flow from marriage," id. at 322, intangibles that are important components of marriage as a "civil right....tatus of same-sex couples and their children as "outliers to the marriage laws." Id. at 335.
First, while marriage is a fundamental right, it is also a status based on contract, and states may regulate contracts. Indeed, the U.S. Supreme Court has held that states can regulate marriage without having to satisfy a heightened standard of review. See Zablocki v. Redhail, 434 U.S. 374 (1978).

Deloitte & Touche LLP | OECD Releases Discussion Draft on Intangibles  — Linex Legal
The draft's broad definition of intangibles using a new, two-pronged test. The potentially controversial approach to identifying parties entitled to intangible-related returns. Identifying transactions involving the use or transfer of intangibles …

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