Study On Transfer Pricing Of Marketing Intangibles

Transfer pricing is one of the most important concepts in the international tax law, which involved the tax issues caused by the profit splitting inside the MNCs and the tax authorities. In recent years, the transfer pricing of marketing intangibles arose and caught the tax authorities' attention. The key issue of the transfer pricing of marketing intangibles is the cost sharing and the profit splitting of the parent company and its foreign associated enterprises.This paper analyzed the Glaxo case between GSK Company and IRS which cause a great influence on the transfer pricing of marketing intangibles. Through the studying of new actions of different countries' tax authorities and OECD on this issue, discuss the solution of the transfer pricing of marketing intangibles.The preface talks about the background of the transfer pricing for marketing intangibles and the purposes of this article.Chapter1 introduces the basic theory of marketing intangibles, including its definition and characteristics; moreover , this part also analyzes the transfer pricing methods of marketing intangibles.Chapter2 presents some special issues of the transfer pricing for marketing intangibles by analyzing Glaxo Case and discusses the solution of the transfer pricing issues for marketing intangibles through the new actions of different countries' tax authorities and OECD.Chapter3 focuses on the transfer pricing issues in our country and provided suggestions on building up legal framework of the transfer pricing of intangibles and taking this as a foundation to give more legal guidance on transfer pricing of marketing intangibles.