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The Research Of The Transfer Pricing Regulation On Marketing Intangible Assets Transnational

Posted on:2018-11-25Degree:MasterType:Thesis
Country:ChinaCandidate:W D SuFull Text:PDF
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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,especially the case of GSK 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 GSK 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.This paper is divided into four parts.The first part mainly by GSK cases involved in the marketing of intangible assets,analyze marketing related issues to the particularity of intangible assets,as well as the existing system is not applicable.The second part elaborates the relevant issues of marketing intangible assets,and expounds and analyses different viewpoints,and concludes the conclusion.The third part elaborates the problems of the marketing intangible assets,and expounds the different viewpoints and the legal analysis.The fourth part elaborates the marketing intangible assets transfer pricing different opinions and legal analysis,finally put forward marketing idea of intangible assets transfer pricing adjustment method.The fifth part mainly discusses the development of the marketing intangible asset problem in China,and puts forward some Suggestions based on the shortage.
Keywords/Search Tags:Transfer Pricing, Marketing Intangibles, Legal Regulation
PDF Full Text Request
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