Intra-Group IP Transfers Following International M&A Transactions – Challenges and Best Practice from a (Swiss) Transfer Pricing Perspective

Abstract

The post-M&A transfer of intellectual property raises a number of challenging questions from a transfer pricing perspective. By means of a case study, the author illustrates the use of international valuation standards in the context of intellectual property and transfer pricing (fair value versus arm’s length principle) as well as the treatment of pricing premiums and milestone payments.