Join Dean Morris as he presents “Transfer Pricing: Best Practices for Intangibles” at the Understanding Canada-US Taxation Conference

June 6 & 7, 2013 Toronto, Canada

Lack of consensus by major tax authorities, as evidenced by recent feedback regarding the Organisation for Economic Co-Operation and Development’s Discussion Draft on Special Considerations for Intangibles, create a challenge for multinationals on establishing best practices for the transfer pricing of intangibles. This workshop outlines how to incorporate principles to create a strong foundation for intangible transfer pricing policies where there is consensus. This workshop also outlines how to measure and mitigate risk where there is lack of consensus. 

Issues covered will include:

• Which of the multiple definitions of intangibles should I use?
• Where is the lack of consensus on the treatment of intangibles?
• What are typical intangible issues from a Canada Revenue Agency and an Internal Revenue Service transfer pricing audit?
• What is the withholding tax issue to manage?
• How does legal structure and valuation timing affect your intangible transfer price?