“Legal Ownership of Intangible Assets versus Economic Substance” - Asia-Pacific Journal of Taxation Volume 21 No.2 (2017)

Anthony Tam, Executive Director of Tax Services at Mazars Hong Kong, wrote an article “Legal Ownership of Intangible Assets versus Economic Substance” for the Asia-Pacific Journal of Taxation Volume 21 No.2 (2017). In the article, Anthony discusses the Organisation for Economic Cooperation and Development (“OECD”)’s perspectives on the BEPS Action Plans 8-10.

This article aims to discuss in more detail the OECD’s approach to the allocation of profits from the creation and exploitation of assets, in particular intangible assets. It also identifies practical approaches that can be used to assist in understanding the significance of various functions and their relevance to the determination of the allocation of profits among different entities that contribute to the creation and exploitation of intangible assets. The transfer pricing documentation under Action Plan 13 is not discussed. The article also discusses China’s position with respect to intangibles. 

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To read the full article, please see the PDF attached below. 

Credits: Anthony Tam for Asia-Pacific Journal of Taxation Volume 21 No.2 (2017)

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