Report on the Application of Economic Valuation Techniques (2017)

Category: Application of Economic Valuation Techniques within the EU (2016/2017), EU Transfer Pricing Reports | Tag: , , , , , , , , , , , , , , , , , , , , ,
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JTPF report valuation
Related content:
  1. EU Study on the Application of Economic Valuation Techniques (2016)
    The Study on the Application of Economic Valuation Techniques for Determining Transfer Prices of Cross Border Transactions between Members of Multinational Enterprise Groups in the EU provides an overview on how valuation techniques can practically and most efficiently be used for transfer pricing purposes in the EU, particularly for transactions involving intangibles. It investigates the differences between valuations for transfer pricing purposes and valuations for other purposes, and the state of play in terms of...
  2. Norway vs Normet Norway AS, March 2019, Borgarting Lagmannsrett, Case No 2017-202539
    The dispute in this case was the price paid in 2013 for an intra-group transfer of intangibles. In January 2013 the Swiss company Normet International Ltd acquired all the shares in the Norwegian company Dynamic Rock Support AS (now Normet Norway AS) for a price of NOK 78 million. In February 2013 all intangibles in Dynamic Rock Support AS was transfered to Normet International Ltd for a total sum of NOK 3.666.140. The Norwegian tax...
  3. Valuation Techniques
    In transfer pricing, valuation of (intangibles) assets are often based on a prior acquisitions of shares in the relevant business – CUT/CUPs. In situations where reliable CUP for a transfer of assets cannot be identified, it may also be possible to use valuation techniques to estimate the arm’s length price for assets transferred between associated enterprises. In particular, the application of income based valuation techniques, premised on the calculation of the discounted value of projected future...
  4. US vs. Amazon, March 2017, US Tax Court
    In 2005 Amazon US entered into a cost sharing arrangement (CSA) with its Luxembourg subsidiary, Amazon Lux. Pursuant to entering the CSA, Amazon US granted Amazon Lux the right to use certain pre-existing intangible assets in Europe, including the intangibles required to operate Amazon’s European website business. This arrangement required Amazon Lux to make an upfront “buy-in payment” to compensate Amazon US for the value of the intangible assets that were to be transferred to Amazon Lux. As consideration for the transfer of pre-existing intangibles, Amazon Lux...
  5. Norway vs Cytec, March 2019, Borgarting Lagmannsrett, Case No 2017-90184
    The question in the case was whether Cytec Norway KS (now Allnex Norway A/S) had paid an arm’s length price for an intra-group transfer of intangible assets in 2010. Cytec Norway KS had set the price for the accquired intangibles at NOK 210 million and calculated tax depreciations on that basis. The Norwegian tax authorities found that no intangibles had actually been transferred. The tax Appeals Committee determined that intangibles had been transferred but only...
  6. Denmark vs H Group, April 2019, Tax Tribunal, Case No. SKM2019.207
    In this case intangibles had been transferred from a Danish subsidiary to a US parent under a written agreement. According to the agreement the Danish subsidiary – which had developed and used it’s own intangibles – would now have to pay royalties for the use of trademarks, know-how and patents owned by the US parent. The tax authorities had issued an assesment on the grounds that the majority of the Danish company’s intangibles had been...