Category: Intangibles – Goodwill Know-how Patents
In transfer pricing the word “intangible” is intended to address something which is not a physical asset or financial asset, which is capable of being owned or controlled for use in commercial activities, and whose use or transfer would be compensated had it occurred in a transaction between independent parties in comparable circumstances.
In discussions of transfer pricing various categories of intangibles are described and labels applied. Distinctions are sometimes made between trade intangibles and marketing intangibles, between “soft” intangibles and “hard” intangibles, between routine and non-routine intangibles, and between other classes and categories of intangibles.
Examples of intangibles are: Patents, Know-how and trade secrets, trademarks, trade names and brands, rights under contracts and government licences, licences and similar limited rights in intangibles, goodwill and ongoing concern value.
![Ireland vs Perrigo, November 2020, High Court, Case No[2020] IEHC 552 (Juridical Review)](http://c9r4v5v2.stackpathcdn.com/wp-content/plugins/pt-content-views-pro/public/assets/images/lazy_image.png)
Ireland vs Perrigo, November 2020, High Court, Case No[2020] IEHC 552 (Juridical Review)

Denmark vs. Software A/S, September 2020, Tax Court, Case no SKM2020.387.LSR

Denmark vs. Adecco A/S, June 2020, Supreme Court, Case No SKM2020.303.HR
Sweden vs Flir Commercial Systems AB, March 2020, Stockholm Administrative Court, Case No 28256-18

Denmark vs Pharma Distributor A A/S, March 2020, National Court, Case No SKM2020.105.OLR

France vs SA Sacla, February 2020, CAA de Lyon, Case No. 17LY04170
Altera asking the US Supreme Court for a judicial review of the 2019 Decision from the U.S. Court of Appeals concerning the validity of IRS regs. on CCAs

Denmark vs Engine branch, January 2020, Tax Tribunal, Case No SKM2020.30.LSR

Denmark vs Adecco A/S, Oct 2019, High Court, Case No SKM2019.537.OLR

Israel vs Broadcom, Aug 2019, Israeli Supreme Court, Case No 2454/19

US vs Amazon, August 2019, US Court of Appeal Ninth Circut, Case No. 17-72922

Uruguay vs Philips Uruguay S.A., July 2019, Tribunal de lo Contencioso Administrativo, Case No 456/2019

Netherlands vs Crop Tax Advisors, June 2019, Court of the Northern Netherlands, Case No 200.192.332/01

Perrigo facing billion dollar tax assessments in both Ireland and the US

Mexico vs “Drink Distributor S.A.”, April 2019, TRIBUNAL FEDERAL DE JUSTICIA ADMINISTRATIVA, Case No 15378/16-17-09-2/1484/18-S2-08-04

Denmark vs H Group, April 2019, Tax Tribunal, Case No. SKM2019.207.LSR

Norway vs Normet Norway AS, March 2019, Borgarting Lagmannsrett, Case No 2017-202539

Norway vs Cytec, March 2019, Borgarting Lagmannsrett, Case No 2017-90184

Blizzard Gaming involved in major Tranfer Pricing disputes
