Guidance on Transfer Pricing Aspects of Intangibles
This document contains revisions to the OECD Transfer Pricing Guidelines to align
transfer pricing outcomes with value creation in the area of intangibles. The changes
clarify the definition of intangibles and provide guidance for related parties; including
transactions involving intangibles and the transfer pricing treatment of local market
features and corporate synergies. Some transfer pricing issues relating to intangibles
are closely related to other issues that are to be addressed during 2015, most notably
in relation to the allocation of risk among MNE group members and recharacterisation
of transactions. Because of those interactions some sections of this document are
in intermediate form and will be finalised in 2015.
Published on September 16, 2014Also available in: French, Korean, Chinese
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