Il Tranfer Pricing nelle transazioni di Intangibles

The aim of the thesis is, first of all, to provide the foundations for a comprehensive understanding of the problems connected to the transfer pricing of intangibles, also through a historical analysis. Secondly, we dealt with the qualification of the concept of "intangibles", still the subject of strong interpretative contrasts, in order also to delimit the scope of the present analysis. Subsequently, the methods for determining the most appropriate arm's length in relation to transactions with intangibles were highlighted, asking the question whether the arm's length is still the most suitable instrument in the face of developments in the current economy. It has been highlighted that the object of comparability must be the transaction, rather than the object of the intangible.In conclusion, it has been found that to date the solutions to the problems connected to the transfer pricing of intangibles find a basis not on the contrast between the adoption of a separate accounting or a unitary apportionment, but on the jointed use of them.