The Quest for Marketing Intangibles

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Audio Webcast | Duration: 90 minutes


In transfer pricing, one of the most challenging issue is the taxation of income from intangible property. Special Bench of Delhi Income-tax Appellate Tribunal (SB) in a batch of cases involving several taxpayers, with the lead case being that of M/s L.G. Electronics India Private Limited (Taxpayer) v Assistant Commissioner of Income-tax pronounced its much awaited ruling. The transfer pricing issue before the SB was whether an affiliate needs to be compensated under arm’s length conditions for "excessive" advertising, marketing and promotional (AMP) expenditure that allegedly enhanced the value of a trademark or brand name legally owned by another affiliate.

This webcast discusses the ruling and transfer pricing aspects/issues relating to Marketing Intangibles.

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Rajendra Nayak

Partner, International Tax Services and Tax Knowledge & Solutions Group

Rajendra Nayak is a Partner with the Knowledge & Solutions Group. He is a Member of ICAI and holds a Masters degree in International Taxation from the Regent University School of Law, USA.

Rajen has been rated by Euromoney's International Tax Review Magazine among the 'Top Tax Dispute Resolution Lawyers and Advisors in India’ for the year 2012.

A noted international tax thought leader, Rajen has over 16 years of experience in tax consulting. He has considerable experience in advising companies on cross-border transactions, transfer pricing planning, documentation & controversy management and assisting companies in international tax planning. He has worked with a number of leading Indian and multi-national companies in the information technology and manufacturing sector.

Rajen is a regular speaker at conferences and has contributed several articles on international taxation. He is the co-author of the Indian chapter of IBFD’s book on Transfer Pricing Controversy and Dispute Resolution.

Vijay Iyer

Partner & National Leader - Transfer Pricing

Vijay Iyer is a tax partner and National Transfer Pricing leader for the International Tax Services practice in Northern India. Vijay has been rated as one of the World’s Leading Transfer Pricing Advisors for India by the Legal Media Group in their annual global guide as well as by International Tax Review. With an experience spanning to nearly two decades, Vijay has been advising clients on domestic and international tax matters.

Vijay is actively involved in Transfer Pricing Litigation, both as an arguing counsel and as an advisor assisting clients in devising their litigation strategy. He regularly appears before various appellate forums including ITAT matters. He has also been actively involved in drafting the Guidance Note on Transfer Pricing issued by the Institute of Chartered Accountants of India.