Transfer pricing and intangible assets: problem areas in addressing the transfer of intangible assets

dc.contributor.authorSiddle, Roberten_ZA
dc.date.accessioned2016-04-05T11:46:09Z
dc.date.available2016-04-05T11:46:09Z
dc.date.issued2014en_ZA
dc.description.abstractIn assessing the problems that arise when the practice of transfer pricing is applied to the transfer of intangible asset transfers there are certain areas and nuances that need to be recognized. These include the distinction between economic and legal ownership and the fact that the two concepts, in certain circumstance, are mutually exclusive. Furthermore, the fact that the traditional methods of transfer pricing may not be able to address the unique nature of certain intangibles and that even the more complex methods involving both parties may fall short in situations where the rights and obligations connected to the intangibles assets are not subject to written agreements or accounting standards and procedures. In delving into the interaction of these two fields I will first establish the playing field and the rules, being the practice of transfer pricing, both on the international stage and domestic level. Next it will be necessary to understand the nature of intangible assets as viewed internationally. Upon reviewing the status of intangible assets in the context of transfer pricing I hope to locate the shortcomings caused by the unique characteristic of intangibles and hopefully will be able to suggest some viable options and alternatives.en_ZA
dc.identifier.apacitationSiddle, R. (2014). <i>Transfer pricing and intangible assets: problem areas in addressing the transfer of intangible assets</i>. (Thesis). University of Cape Town ,Faculty of Law ,Department of Commercial Law. Retrieved from http://hdl.handle.net/11427/18614en_ZA
dc.identifier.chicagocitationSiddle, Robert. <i>"Transfer pricing and intangible assets: problem areas in addressing the transfer of intangible assets."</i> Thesis., University of Cape Town ,Faculty of Law ,Department of Commercial Law, 2014. http://hdl.handle.net/11427/18614en_ZA
dc.identifier.citationSiddle, R. 2014. Transfer pricing and intangible assets: problem areas in addressing the transfer of intangible assets. University of Cape Town.en_ZA
dc.identifier.ris TY - Thesis / Dissertation AU - Siddle, Robert AB - In assessing the problems that arise when the practice of transfer pricing is applied to the transfer of intangible asset transfers there are certain areas and nuances that need to be recognized. These include the distinction between economic and legal ownership and the fact that the two concepts, in certain circumstance, are mutually exclusive. Furthermore, the fact that the traditional methods of transfer pricing may not be able to address the unique nature of certain intangibles and that even the more complex methods involving both parties may fall short in situations where the rights and obligations connected to the intangibles assets are not subject to written agreements or accounting standards and procedures. In delving into the interaction of these two fields I will first establish the playing field and the rules, being the practice of transfer pricing, both on the international stage and domestic level. Next it will be necessary to understand the nature of intangible assets as viewed internationally. Upon reviewing the status of intangible assets in the context of transfer pricing I hope to locate the shortcomings caused by the unique characteristic of intangibles and hopefully will be able to suggest some viable options and alternatives. DA - 2014 DB - OpenUCT DP - University of Cape Town LK - https://open.uct.ac.za PB - University of Cape Town PY - 2014 T1 - Transfer pricing and intangible assets: problem areas in addressing the transfer of intangible assets TI - Transfer pricing and intangible assets: problem areas in addressing the transfer of intangible assets UR - http://hdl.handle.net/11427/18614 ER - en_ZA
dc.identifier.urihttp://hdl.handle.net/11427/18614
dc.identifier.vancouvercitationSiddle R. Transfer pricing and intangible assets: problem areas in addressing the transfer of intangible assets. [Thesis]. University of Cape Town ,Faculty of Law ,Department of Commercial Law, 2014 [cited yyyy month dd]. Available from: http://hdl.handle.net/11427/18614en_ZA
dc.language.isoengen_ZA
dc.publisher.departmentDepartment of Commercial Lawen_ZA
dc.publisher.facultyFaculty of Lawen_ZA
dc.publisher.institutionUniversity of Cape Town
dc.subject.otherTax Lawen_ZA
dc.titleTransfer pricing and intangible assets: problem areas in addressing the transfer of intangible assetsen_ZA
dc.typeMaster Thesis
dc.type.qualificationlevelMasters
dc.type.qualificationnameLLMen_ZA
uct.type.filetypeText
uct.type.filetypeImage
uct.type.publicationResearchen_ZA
uct.type.resourceThesisen_ZA
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