Fri, Dec 29, 2017

Duff & Phelps' Global Transfer Pricing Specialists Published in Bloomberg BNA's Transfer Pricing Forum: December 2017 Issue

Read full article

Managing Directors Patrick McColgan and Danny Beeton and Directors Leda Zhuang and Stean Hainsworth, from Duff & Phelps' Global Transfer Pricing Practice, provide U.S., UK and Australia perspectives on "Services or Intangible Property Transfer? - Senior Technical and Management Personnel Transfers". In the December 2017 issue of Bloomberg BNA's Transfer Pricing Forum, the topic covered included commentary on the following:

Services or Intangible Property

  1. If a senior manager or management team is relocated into or out of your jurisdiction, does your country have a view about whether the transfer is purely a services transfer, or includes an intangible asset such as goodwill (or even workforce in place); or of an intangible such as profit potential?
  2. What factors would be considered to determine how to characterize this transfer? In particular, might it make a difference whether it is a single person or a group of managers?
  3. What difference might the duties of the management team make? (For example, suppose this was a sales person or team, as opposed to a management team? Or an R&D group?)

Valuing the Item Transferred

  1. Are there any local tax or valuations rules or conventions on such valuations? How would the Hard-To-Value Intangibles concepts apply?

Supporting the Company

  1. What features does a transfer pricing policy need in order to use it to support a calculation of this value reliably (given that the management team provides current services but may also be involved in important intangible asset DEMPE decisions)?

Valuation Advisory Services

Our valuation experts provide valuation services for financial reporting, tax, investment and risk management purposes.

Transfer Pricing

Kroll's team of internationally recognized transfer pricing advisors provide the technical expertise and industry experience necessary to ensure understandable, implementable and supportable results.

Tax Services

Built upon the foundation of its renowned valuation business, Kroll's Tax Service practice follows a detailed and responsive approach to capturing value for clients.