continues to establish an international order for free and fair taxation.
Valuation of the Intellectual Property
Among the transfer pricing transactions of MNE Groups, intellectual property (IP)- related transfer prices are the most significant and susceptible to manipulation. This is a result of IP's high value and mobility and the complexity of IP-related issues. IP 本文来自辣.文,论-文·网原文请找腾讯324，9114 issues exist in commercial practices, valuation, and accounting as well as in attribution of income for tax purposes. These intricate financial issues are often complex and in a state of flux. Consequently, tax avoidance through transfer pricing manipulation of IP is a growing
problem.
Treaty Shopping
Treaty shopping is a graphic expression used to describe the act of a resident of a third country taking advantage of a fiscal treaty between states. Since various tax treaties
concluded between states provide differences in tax burdens and different benefits,
taxpayers tend to look for tax planning options. The taxpayer is interested in how to conduct business and personal transactions so that taxes are reduced or even eliminated. The ensuing search for such advantages is generally referred to as ‘tax treaty shopping’.
The rationale behind providing relief is to create a balance in the taxpaying rules of respective nations in a transnational transaction. It is a device that involves routing of income arising in one country to a person in another country through a third country.
For Example,
X is a resident of country A
X receives interest from country B which is subject to tax in B (15 percent)
A does not have a tax treaty with B
A has a tax treaty with C withholding tax is 5%.
B also has a tax treaty with C withholding tax is 5%
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