Please use this identifier to cite or link to this item: http://hdl.handle.net/10419/110842
Authors: 
Richter, Wolfram F.
Breuer, Markus
Year of Publication: 
2015
Series/Report no.: 
CESifo Working Paper 5340
Abstract: 
The adequate pricing of intellectual property (“IP”) for tax reporting is a largely unsettled issue. Transactional profit-based methods are on the rise although only rated as “methods of last resort” by the OECD. This paper focuses on regulated profit splitting and compares this transfer pricing rule with one allowing multinationals to price IP freely subject to the constraint that the price used for tax reporting is also used internally. The standard of comparison is global efficiency in R&D. The model is one of second best. It allows for internationally differentiated tax rates and non-deductible effort costs in the production of know-how.
Subjects: 
transfer pricing rule
intellectual property
profit split method
allocational efficiency
second-best policy
JEL: 
H25
O34
M48
F23
Document Type: 
Working Paper

Files in This Item:
File
Size





Items in EconStor are protected by copyright, with all rights reserved, unless otherwise indicated.