How does BEPS resolve the transfer pricing risk - Resulting from royalties and assets such as goodwill, patent and brands, trademarks and tradenames.

Abstract

This paper aims at assessing the intangibles issues in related to BEPS issues by focusing in strategies that been provided by OECD. Its consist transfer pricing issues and methods in order to solve those issues, also some examples from intangibles such as royalties, goodwill, patent and brands, trademarks and tradenames. This paper complements previous studies by estimating and comparing the tax elasticities of different types of intangibles. And contain examples of Starbucks an Google in order to highlighted those issues.