Michelle Markham (Queensland University of Technology Faculty of Law (Brisbane, Australia)) has published Tax in a Changing World: The Transfer Pricing of Intangible Assets, 40 Tax Notes Int’l 895 (Dec. 5, 2005), also available on the Tax Analysts web site as Doc 2005-21882, 2005 WTD 234-10:
The spiraling cross-border trade in intangibles has compelled tax authorities worldwide to scrutinize their tax treatment of those assets, as traditional tax practices are becoming increasingly difficult to apply, particularly when unique or high-value intangibles are involved.
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