Podatkowa polityka cen transferowych w zakresie dóbr niematerialnych w kontekście BEPS
Transfer Pricing Tax Policy Concerning Intangibles in the Context of BEPS

Summary/Abstract: This paper aims to present the recent tax developments of transfer pricing in connection with BEPS Action 8. Special measures proposed by the OECD providing guidance as to how tax assessment of transactions concerning intangibles between associated enterprises should be reconsidered. One of the crucial issues is the appropriate allocation of profits in accordance with the arm’s length principle. The focus is laid on the creation of value at transfer or the use of intangibles and on the developing transfer pricing rules for hard-to-value intangibles.

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