In the first in a series of articles from Global Tax Weekly, NERA Affiliated Consultant Dr. Alexander Voegele and Consultant Philip de Homont present a case study demonstrating how the relocation of old, well-established brands in times of base erosion and profit shifting (BEPS) can be mastered by a careful dissection of intellectual property into various usage rights.
Further articles in this series will deal with Transfer Pricing Planning and Transfer Pricing Defense cases, as well as exploring in more depth some of the technical issues raised in this first case study.
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