Meeting of the Minds—IP Transfer Pricing: The Key Essentials

Vol. 5 No. 1


Anne Fairpo is a barrister at 13 Old Square Chambers in London, England, where she specializes in taxation of intellectual property and international tax. Ms. Fairpo can be reached at Jillian A. Centanni is an intellectual property associate at Gibbons P.C. in Newark, New Jersey. She recently graduated from Rutgers School of Law in Camden and additionally holds an M.B.A. from the Illinois Institute of Technology and a B.S.E. in chemical engineering from the University of Michigan. She can be reached at This article was the result of collaboration between members of the ABA’s Young Lawyer Division; Committee 465, Taxation, Bankruptcy and Security Interest; and Committee 112, Patent Litigation.

The world is no longer a place where corporations provide goods and services in one state or even one country. As a result of globalization or the relationships among people, culture, and economic activity around the globe, most corporations manage production and deliver services in multiple countries. For example, although it’s a rough measure, exports have increased from just over 12% of the global gross domestic product (GDP) to almost 28% of the GDP between 1960 and 2011.1

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