[INTM441130] Transfer Pricing: Transactions and Structures: business structures: valuable intangibles
Intangibles used by business come in many forms, e.g. brand names, trademarks, patents, know-how, manufacturing processes, software, etc. Careful consideration should be given to whether payments for the use of an intangible by one group company to another which owns the intangible are at arm's length amounts.
It can be difficult to move existing intangible assets without tax consequences. From a tax-planning point of view, it is better to move intangibles at a time of merger or acquisition, or arrange matters so that intangibles are created offshore in a favourable location.
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