Overview of IP Migration Models

Martin Schmitt (), Anna-Katharina Christen () and Merten Zenker ()
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Martin Schmitt: Deloitte GmbH
Anna-Katharina Christen: Deloitte
Merten Zenker: Deloitte GmbH

A chapter in Intangibles in the World of Transfer Pricing, 2021, pp 27-47 from Springer

Abstract: Abstract Globalization, along with increased digitalization, often leads to the need for business restructurings of multinationals, in particular with regard to consolidation of the group’s intangibles for a number of reasons. Connected with this need, different questions arise from a business perspective as well as from a tax perspective. This chapter will outline the various aspects of an IP migration from different angles and highlight typical IP migration models seen in practice. Further, the history and recent developments on an international level with regard to the competition between tax systems for IP will be outlined as well as typical limitations and drawbacks.

Keywords: IP migration; Business restructuring; Principal model; IP regimes (search for similar items in EconPapers)
Date: 2021
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Persistent link: https://EconPapers.repec.org/RePEc:spr:sprchp:978-3-319-73332-6_3

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DOI: 10.1007/978-3-319-73332-6_3

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