Transfer pricing landscape and profit-shifting behaviour through intangible assets relocation: an empirical analysis from Italian multinational corporations

Abstract

This thesis discusses the challenges related to the determination of transfer pricing, in the specific case of intangible assets, with the application of the arm’s length principle. With the rise of technological innovation, intangibles have gained a solid foothold in the global markets. The ownership of assets, such as intellectual property, bring significant competitive advantage to the firm. Because of their ambiguous nature, they are likely to be exploited also for elusive tax purposes through profit-shifting behaviour. By means of an empirical analysis, it will be investigated which factors influence the location decision of intangible assets among the affiliates of Italian multinational firms and to what extent.