
doi: 10.2139/ssrn.3140026
This paper is about the controlled transactions in the case of intangibles. The intangibles have characteristics which are similar with than of tangibles. Through transfer pricing we have rights which granted from some companies to other, to achieve the appropriate profits and to minimize the losses. The transfer of intangibles allows the allocation of profits and losses, with that way to comply with the arm’s length principle. Thereupon, intangibles are included in the property or services to serve the business plan of enterprises which participate in controlled transactions.
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