Transfer pricing: Udnyttelse af immaterielle aktiver

Mads Skovgård Mikkelsen & Jesper Petersen

Student thesis: Diploma thesis


This report is made by Mads Skovgård Mikkelsen and Jesper Petersen as their final project as Graduate Diploma in Accounting and Financial Management, at Copenhagen Business School in May 2021. In this report we will examine what an intangible asset is, how to establish the ownership, which factors that could impact the valuation and which methods there can be used for valuation of an intangible asset, while still complying to the arm’s length principles. The main focus in this report is analyzing the transfer pricing guidelines, made by the OECD, with special focus on intangible assets, and the rules for documenting an controlled internal transaction. We will also establish what the arm’s length principle is, and how this applies to an internal controlled transaction. The OECD-transfer pricing guidelines, regulates that every country in the OECD have a common set of rules, that which an internal controlled transaction have to apply to, and therefore secures that taxation in all the member countries is fair and equal, and secures that the companies avoid double taxation. It also sets up barriers for companies to transfer assets to countries with more beneficial taxation on company profits, and therefore secures that all assets are taxed in the corresponding countries. In this report we will have our focus on OECD-transfer pricing guidelines chapter six, regarding intangible assets, and the regulation made especially on these. We will also include the specific guidelines for which documentation the companies have to produce, when making a valuation of an internal controlled transaction, and which methods the OECD suggest using in making these valuations. We will be analyzing these models, identify the strength and weaknesses of each, and how they apply on the valuation on immaterial assets.

EducationsGraduate Diploma in Accounting and Financial Management, (Diploma Programme) Final Thesis
Publication date2021
Number of pages77