Recent Publications

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IP Valuation & Transfer Pricing
Volkswagen AG & Audi AG

Economic implications of automatic injunctions in German patent litigation

Automatic injunctive relief in German patent law shifts bargaining power between a patentee (plaintiff) and a defendant to the patentee. This will impact both settlement behaviour and the settlement payment....

IP Valuation & Transfer Pricing
Public Consultation Document - Addressing the Tax Challenges of the Digitalisation of the Economy

Additional clarification is still to be provided in the new OECD guidance on marketing intangibles

The Marketing Intangible Proposal presented in the OECD’s Public Consultation Document (released on February 13, 2019) does not provide taxpayers and tax administrations with a clear guidance on the potential...

IP Valuation & Transfer Pricing
Public Discussion Draft – Financial transactions

Additional guidance is still to be provided in order to fully clarify the transfer pricing issues related to financial transactions

The newly released public Discussion Draft “BEPS ACTIONS 8 – 10, Financial transactions” (the “Discussion Draft”) provides additional guidance to taxpayers and tax administrations on how to deal with controlled...

IP Valuation & Transfer Pricing
Italian Ministry of Economy and Finance – Public Consultation on Transfer Pricing

THE ITALIAN GUIDELINES ON THE ARM’S LENGTH PRINCIPLE NEED FURTHER CLARIFICATION

The proposed draft Transfer Pricing guidelines released by the Italian Ministry of Economy and Finance (MEF) on 21 February 2018 fail to provide a clear guidance on how to evaluate...

IP Valuation & Transfer Pricing
Public Discussion Draft - Hard to Value Intagibles

Draft OECD guidance on hard to value intangibles (HTVIs) allows tax authorities to use hindsight in their tax assessments – honestly?

The newly released public Discussion Draft “Implementation Guidance on HTVI” (the “Discussion Draft”) aims at tackling the information asymmetry between the taxpayer and the tax administration. In particular, the tax...

IP Valuation & Transfer Pricing
Public Discussion Draft - Revised Guidance on Profit Splits

3 reasons to question whether the new OECD Guidance on Profit Split is fit for purpose

The Discussion Draft “Revised Guidance on Profit Splits” released by the OECD 22 June 2017 does not provide taxpayers and tax administrations with a thorough and univocal guidance on when...