| All along, the transfer pricing issues are the focus of international tax. Due to the particularity of intangible assets, disputes relating to transfer pricing of intangibles are more and more recent years, especially marketing intangibles.As the international recognition of marketing intangibles transfer pricing, most countries have formulated relevant laws and regulations. The BEPS plan of OECD will also include intangible transfer pricing. "Intangible transfer pricing guidelines" released by OECD in September 2014, made a detailed guidance to the intangible transfer pricing analysis, which means the international attention on the intangible transfer pricing. But in China, the regulation of the marketing intangibles is still a backward stage. This paper focus on the marketing intangibles, through elaborate theory, case studies, international comparisons and make recommendations to enhance the marketing intangibles and respond actively to the adjustment by BEPS. In addition, this paper illustrates and analyzes the "Implementation Measures for Special Tax Adjustments" draft published in 2015 to provide a reference for policy-related issues of the regulation of the marketing intangible transfer pricing. |
