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Dr. Alexander Voegele

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Transfer Pricing

Migration of a Well-Known Brand

30 November 2011
By Philip de Homont and Dr. Alexander Voegele et al.

This article is the ninth in a series of ten articles produced by International Tax Review on tax-effective intellectual property management. The article provides a case study of how to structure the migration of a well-known brand. The case focuses on a multinational group that had acquired a large number of consumer goods companies over the years. These consumer goods companies had very well-known brands, which historically had been built up by the respective companies on their own. After some time, the holding company introduced, among other things, centralized brand management, which caused significant challenges for the group. In this article, the authors conduct a careful analysis of the case to demonstrate how the transfer of the brand should be remunerated and exit taxation could be avoided.