In the wake of BEPS reforms and the global pandemic, corporate reorganizations, whether driven by commercial needs or efforts to reduce controversy risks, often involve the restructuring of intangible assets and related R&D functions. These changes must be carefully assessed through the lens of transfer pricing rules outlined in the OECD Guidelines, along with the specific interpretations adopted by individual jurisdictions.

At the same time, there has been a noticeable rise in tax audits and litigation concerning transfer pricing and intangibles. Common areas of dispute include royalty rates, cost-sharing arrangements, and the transfer of intangibles within multinational groups. This webinar explores the key pressure points that frequently lead to such disputes, strategies for managing these risks, and the potential implications of the OECD’s two-pillar framework on the future structuring of intangibles and R&D activities.

• Pinpoint the sections of the OECD Transfer Pricing Guidelines on intangibles that are most likely to trigger cross-border tax disputes.
• Examine the main challenges multinational enterprises face when determining arm’s length pricing for R&D activities and transactions involving the use or transfer of intangible assets.
• Review recent policy developments and case law to understand how legislative changes and judicial decisions are shaping transfer pricing practices related to intangibles.