EU Study on the Application of Economic Valuation Techniques (2016)

Category: Application of Economic Valuation Techniques within the EU (2016/2017), EU Transfer Pricing Reports | Tag: ,
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    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...
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    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...
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  5. France vs. Havas, July 2017, CE, No 400644
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  6. Israel vs Broadcom, December 2019, Lod District Court, Case No 26342-01-16
    Broadcom Semiconductors Ltd is an Israeli company established in 2001 under the name Dune Semiconductors Ltd. The Company is engaged in development, production, and sale of components to routers, switches etc. The shares in Dune Semiconductors were acquired by the Broadcom Corporation (a US group) in 2009 and following the acquisition intellectual property was transferred to the new Parent for a sum of USD 17 million. The company also entered into tree agreements to provide marketing...