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Overview of IP Migration Models

In: Intangibles in the World of Transfer Pricing

Author

Listed:
  • Martin Schmitt

    (Deloitte GmbH)

  • Anna-Katharina Christen

    (Deloitte)

  • Merten Zenker

    (Deloitte GmbH)

Abstract

Globalization, along with increased digitalization, often leads to the need for business restructurings of multinationals, in particular with regard to consolidation of the group’s intangibles for a number of reasons. Connected with this need, different questions arise from a business perspective as well as from a tax perspective. This chapter will outline the various aspects of an IP migration from different angles and highlight typical IP migration models seen in practice. Further, the history and recent developments on an international level with regard to the competition between tax systems for IP will be outlined as well as typical limitations and drawbacks.

Suggested Citation

  • Martin Schmitt & Anna-Katharina Christen & Merten Zenker, 2021. "Overview of IP Migration Models," Springer Books, in: Björn Heidecke & Marc C. Hübscher & Richard Schmidtke & Martin Schmitt (ed.), Intangibles in the World of Transfer Pricing, edition 1, pages 27-47, Springer.
    • Handle: RePEc:spr:sprchp:978-3-319-73332-6_3
    DOI: 10.1007/978-3-319-73332-6_3
    as

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