Intangible Transactions and Profit Allocation in the Semiconductor Industry
Journal
Country
Chinese Taipei
Published Date
Issue
International Transfer Pricing Journal 2021 (Volume 28), No. 4
Document
Intangible assets are the core value of the semiconductor industry. Complexity arises in the profit allocation among related parties because the arm’s length principle is hard to apply due to the unique nature of intangible transactions. This article explores the commercial activities of the semiconductor business and analyses possible solutions from some BAPA cases in local practice.