摘要：Cross-border economic activities inherently entail significant tax risks. On the other hand, economic operators can also make significant tax savings with efficient tax planning strategies. This view is supported by some recent high-profile examples of the world’s largest multinational companies (MNCs), which were apparently taxed at relatively low tax rates. MNCs’ ownership of high-value intangible assets (e.g. copyrights, patents, trademarks) plays a central role in the shaping of their tax strategy. The main aim of this paper is to analyse the ways in which existing norms of international tax law give leeway for tax planning techniques tailored for MNCs owning intangibles. The paper explores the main features of the standard techniques used to achieve tax efficient treatment of intangibles in a cross-border context. A detailed analysis of one of the best practical examples – tax strategy of Google – is provided in order to illustrate the phenomenon of profit shifting within a corporate group.
