000			01788nab a2200229 c 4500
999			_c143161 _d143161
003			ES-MaIEF
005			20201111123826.0
007			ta
008			201111t2020 ne ||||oo|||| 00| 0|eng d
040			_aES-MaIEF _bspa _cES-MaIEF
100	1		_968559 _aBerndsen, Nina
245			_aProfit allocation based on scarcity value _ba new factor for taxing intra-group services where they create value _c Nina Berndsen
260			_c2020
500			_aResumen.
520			_aIn this article, it is argued that the principle of taxing where value is created is currently not applied in a way that actually results in taxation where value is created. In order to better adhere to this principle, the scarcity value of intra-group services provided cross-border should be taken into account. The scarcity value entails that the provision of a service in a jurisdiction where it is not possible to obtain that service due to scarcity in the market of that jurisdiction for that specific service gives rise to a relatively higher profit in that jurisdiction. This means that relatively more value is created in that jurisdiction. This additional value should be allocated there in order for that jurisdiction to tax the part of the profit that is created there. The proposal in this article goes beyond the traditional transfer pricing rules and the arm's length principle, but it does not necessarily go against it, as it functions within the framework of the OECD's Marketing Intangibles proposal and the Unified Approach under Pillar One.
650		4	_948095 _aPRECIOS DE TRANSFERENCIA
650		4	_967011 _aCREACIÓN DE VALOR
650		4	_932314 _aBENEFICIOS
650		4	_947647 _aLOCALIZACION
773	0		_9163767 _oWTJ/2020/4 _tWorld Tax Journal _w(IEF)62814 _gv. 12, n. 4, 2020
942			_cRE