Denmark's new transfer pricing IP valuation guideline

Skat's (Denmark's tax authorities) have issued new guidelines on IP valuation entitled "Transfer Pricing, controlled transactions, valuation". Google's handy translation tool will translate the lengthy download in the link for interested readers. Deloitte's summary provides the once over:

"The new guidelines significantly change the generally accepted approaches to valuing individual intangible assets, as well as entire businesses, for Danish transfer pricing purposes. The guidelines focus on forward-looking valuation approaches, which are generally in line with the methodologies followed by most taxpayers. However, the documentation requirements included in the guidelines are broad and extensive and not well-defined. Accordingly, the guidelines should be considered in detail when contemplating IP or business reorganizations involving Danish groups or entities." Deloitte

Transfer Pricing Focus Study by E&Y: Africa

Transfer pricing is the most important international tax matter after valued-added tax and double taxation [affecting SA multinationals], according to a study released by Ernst & Young at the weekend and reported by Business Day here. SA, Namibia, Kenya, Mozambique, and Tanzania have introduced laws dealing with transfer pricing. Other countries tax multinational companies’ transactions under anti-avoidance sections of their domestic tax legislation. About 40% of multinational companies in Africa prepare documentation on a single country basis, modified to meet the needs of specific jurisdictions, rather than on the co- ordinated basis. More than 20% of companies acknowledged that they did not prepare transfer pricing documentation. The research was based on independent interviews with 40 participants in Anglophone Africa in August and September last year.