Dr. George Korenko Addresses Transfer Pricing in Tax Management’s Transfer Pricing Report
Dr. George Korenko, a partner at Edgeworth, addresses transfer pricing issues in his article “Using Internal Agreements to Price Intangibles Transfers” in Tax Management’s Transfer Pricing Report.
In light of the OECD’s questions regarding the availability and use of CUTs for intangibles, Dr. Korenko addresses the issues of comparability and adjustments for potential CUTs and how they can be used to reliably apply the comparable uncontrolled price method. He explains why multinational firms that are active participants in the marketplace for similar intangibles are likely to have potential CUTs in their licensing portfolios. He also shows how firms that are active in in-licensing and out-licensing these technologies often prepare financial analyses that are useful for determining profit potential and making reliable adjustments where necessary.
Dr. Korenko is an expert in transfer pricing and has written extensively about this topic. For more information about his publications and experience in transfer pricing, please contact Dr. Korenko.