Duff & Phelps' Global Transfer Pricing Specialists Published in Bloomberg BNA's Transfer Pricing Forum: December 2017 Issue

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Managing Directors Patrick McColgan and Danny Beeton and Directors Leda Zhuang and Stean Hainsworth, from Duff & Phelps' Global Transfer Pricing Practice, provide U.S., UK and Australia perspectives on "Services or Intangible Property Transfer? - Senior Technical and Management Personnel Transfers". In the December 2017 issue of Bloomberg BNA's Transfer Pricing Forum, the topic covered included commentary on the following:

Services or Intangible Property

  1. If a senior manager or management team is relocated into or out of your jurisdiction, does your country have a view about whether the transfer is purely a services transfer, or includes an intangible asset such as goodwill (or even workforce in place); or of an intangible such as profit potential?
  2. What factors would be considered to determine how to characterize this transfer? In particular, might it make a difference whether it is a single person or a group of managers?
  3. What difference might the duties of the management team make? (For example, suppose this was a sales person or team, as opposed to a management team? Or an R&D group?)

Valuing the Item Transferred

  1. Are there any local tax or valuations rules or conventions on such valuations? How would the Hard-To-Value Intangibles concepts apply?

Supporting the Company

  1. What features does a transfer pricing policy need in order to use it to support a calculation of this value reliably (given that the management team provides current services but may also be involved in important intangible asset DEMPE decisions)?
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