Acquired Intangibles — Transfer Pricing vs. Valuation

Valuing acquired intangibles across tax and financial reporting

Acquisitions of intangible assets, including goodwill, customer relationships, technology-based assets, and intellectual property, can be a meaningful business accelerant. However, these assets may also raise complex accounting, valuation, and transfer pricing questions.

In this course, participants learn how acquired intangibles are identified and classified for financial reporting purposes and why those conclusions may differ from transfer pricing analyses. It compares fair value concepts under financial reporting with the arm’s-length and commensurate-with-income standards used for transfer pricing.

Practical tax risk considerations

Among many other key takeaways, the course addresses enforcement trends in transfer pricing for intangibles, highlighting areas of heightened scrutiny by tax authorities.

From common audit risk factors to staying clued up on evolving documentation expectations and the growing emphasis on economic substance in evaluating intercompany arrangements, learn how robust valuation methodologies and well-supported assumptions are critical to sustaining defensible positions under examination.

Plus, learners will be introduced to important U.S. and global international tax considerations, including the following:

• Section 367
• Global intangible low-taxed income (GILTI), now known as net controlled foreign corporation tested income (NCTI)
• Base erosion and anti-abuse tax (BEAT)
• Foreign tax credits
• Global Anti-Base Erosion Model Rules, better known as Pillar Two

By the end of this course, participants should have greater confidence in designing, documenting, and defending globally compliant intercompany valuation strategies.

Who Will Benefit

• Tax professionals advising multinational companies
• Transfer pricing professionals
• Valuation professionals
• Accounting and finance professionals involved in M&A or purchase accounting
• CPAs working with acquired intangibles or cross-border intellectual property transactions

Key Topics

• Acquired intangible assets
• FASB Accounting Standards Codification® (ASC) 805 and 820 valuation concepts
• Transfer pricing valuation methods
• Arm’s-length and commensurate-with-income standards
• IRS enforcement trends and audit risk
• International tax considerations for acquired intellectual property
• Pillar Two considerations

Learning Outcomes

• Identify acquired intangible assets, including goodwill, customer relationships, and technology-based intangibles, as well as their treatment under current accounting standards.
• Differentiate between the valuation of intangibles for tax and financial reporting purposes.
• Recognize transfer pricing enforcement trends related to intangibles, including audit risks, documentation standards, and valuation defensibility in intercompany transactions.
• Recognize international considerations in transfer pricing, including jurisdictional differences, global compliance standards, and the role of OECD guidelines in shaping policy and enforcement.