Abstract
The creation, purchase and exploitation of intangible assets especially within multinational enterprises has seen a steady increase in recent years. This is because intangible assets provide a competitive advantage, improves communication and workforce skills whilst also improving on business and decision making processes. However, this advantage has led to increased profits being realised by multinational enterprises and as such, major concerns were raised over the taxation thereof by tax authorities globally. It is this concern combined with the difficulties faced in attempting to identify and value intangible assets which gave rise to Chapter VI of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (published in July 2017) which is solely dedicated to intangible assets with a specific focus being placed on the treatment of hard-to-value intangibles from a transfer pricing perspective...
M.Com. (South African and International Taxation)