부산대학교 도서관

Discusses the concept of marketing intangibles. Comments on US transfer pricing rules and case law illustrating the evolution of the marketing intangibles concept, including DHL Corp v Internal Revenue Commissioner on whether the Internal Revenue Service could impute a trademark royalty for the use of the DHL trade name by the company's foreign affiliates. Notes the Organisation for Economic Development (OECD) discussion of the impact of marketing intangibles on the allocation of profits to headquarters or permanent establishments. Compares the approach of the German, Dutch, French, Japanese and Australian tax authorities to marketing intangibles.