This book provides a practical and technical guide to tax treatment and transfer pricing of intangibles such as patents, knowhow, copyrights, trademarks, exploitation rights etc. Starting with the issues involved in identification and taxation of transactions in intangibles and rights, the book goes on to discuss the nuances of finding the arm’s length range of royalty rates, IP transfer, Hard to Value Intangibles, marketing intangibles, corporate guarantee, and value at risk.

There is a dearth of literature on the practical aspects of income tax and transfer pricing practice; this book seeks to rectify that. The book discusses methods and models of benchmarking of intangibles, and goes on to demonstrate – step by step – how these methods and models can be used to arrive at the arm’s length standard. The nuances arising from assessment and litigation trends have also been highlighted.

Models Discussed in the Book

IP transfer

Excess earning method

Relief from Royalty method

Comparable companies’ quoted multiples method

Replacement cost method

Royalty rates

CUT and CUP

Residual Profit Split Method

Investment Rate of Return Method

Projected Incremental Return Method

Option Pricing Method

Nash Bargaining Solution

Corporate Guarantee

Credit default Swaps as CUP

Loss Given Default Method

Yield Spread Method

Hull-White Model

Options Pricing Method

AMP Expenses

Brightline test & ABC test

Residual Profit Split Method

RPSM with aggregation of royalty and AMP

Basic Amortisation Method

Weighted Amortisation Method

Risk Adjustment

Capital Asset Pricing Model

Urken-Barbera Method

Prabhakar Reddy Method

IP Structuring

Back-to-back licensing model

Software IP migration model

Cost Sharing Arrangements

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Wolters Kluwer's Tangible Guide to Intangibles Identification, Valuation, Taxation & Transfer Pricing by Smarak Swain

Publisher: CCH Wolter Kluwer
Book Code: 9789389702743
Availability: 10

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