Transfer pricing and intangibles

the long version

General report (by Toshio Miyatake) and branch reports on transfer pricing and intangibles, one of the topics of the 61st congress of the International Fiscal Association in Kyoto, 2007. The reports addresses intangible property transaction in connection with transfer pricing taxation principles, including the definition of intangible property, the ownership of intangible property, the transfer of intangible property, determining the arm's length price of intangible property, advance pricing agreements, and resolution under the mutual agreement procedure and arbitration.