In the modern world under conditions of free competition companies widely use different kinds of intangible assets in their business (trademarks, logos, technologies, trade secrets, "know-how"). However, in many cases the purpose of their use is to obtain unjustified tax benefits. The article reviews the most common types of transactions of Russian companies with intangible assets, and gives special consideration to resulting tax risks. The author has made an in-depth analysis of arbitration practice related to the subject under investigation and offered practical recommendations on such tax risks minimization for Russian companies.
Keywords: OECD, related parties, transfer pricing, intangible assets, royalties
References:
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