Introduction
Inter-company pricing embraces some basic concepts. Those principles emanate from virtues of corporate structures that have related ownership of entities. The dealings between related entities brings into play arms length standards applicable to related entities. (See TaxConnections, April 24, 2014, Introduction to Section 482 and International Financial Centers) These governing guidelines are promulgated by regulation particularly to conduit entities that provide sales, services, personal property, and intangible property entities that compliment global enterprise of a parent or subsidiary. This writing focuses upon the guidelines that establish the borders of intangible property. Read More
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