Articles in Industry Insights
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Transfer Pricing in the Consumer Goods Sector: A Sector Deep Dive
A practical look at transfer pricing for consumer goods multinationals: brand IP, distribution structures, marketing intangibles, and the challenges of e-commerce and direct-to-consumer models.
Transfer Pricing in the Technology Sector: A Sector Deep Dive
A deep dive into transfer pricing for software and SaaS companies, including IP migration, cost-sharing arrangements, distribution structures, and the unique challenges of digital business models.
Transfer Pricing in Industrial Manufacturing: A Sector Deep Dive
A practical examination of transfer pricing for industrial manufacturing groups: manufacturer characterization (full-fledged, contract, toll), the aftermarket and service-parts business, engineering and NRE charge-outs, joint ventures and licensing, and the interaction with customs and Section 232 tariffs.
Transfer Pricing in Consumer Electronics: A Sector Deep Dive
A practical examination of transfer pricing for consumer electronics groups: layered IP value chains, contract and toll manufacturing characterization, royalty pricing for semiconductor and brand IP, regional distribution structures, and the acute interaction with US tariffs and customs valuation.
Transfer Pricing for Asset Managers: A Sector Deep Dive
A practical examination of transfer pricing for traditional asset managers: management and performance fee allocation, services-based versus profit-split approaches, sub-adviser fee splits, substance requirements, and benchmarking across asset class and strategy.