Intellectual property (IP) in the automotive industry: transfer pricing issues

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Transfer pricing taxation rules place a huge burden on multinational taxpayers. The way intellectual property is created, used and shared governs how profits are recognised for tax purposes. This is an increasingly significant focus for tax authorities, who understand that profits made at the (consolidated) group level are not necessarily reflected at a local level.

This paper addresses transfer pricing in the context of an automotive group. Auto industry specifics can make the analysis different to other sectors and, consequently, may create more conflicts between taxpayers and the authorities.