In July, the OECD published a revised discussion draft on the transfer pricing of intangibles. Deborah Green considers the practical implications for multinational groups with valuable intellectual property.
On 30 July 2013 the OECD published a revised discussion draft (‘the draft report’) on the transfer pricing aspects of intangibles. The report is expected to be finalised in late 2013 or early 2014 and my expectation is that the current draft is very close to the wording we will see in the final draft. Tax Journal readers returning from their summer holidays may have put this in the ‘to read later’ pile but in light of the unusually prescriptive style of the language and the fact that the guidance is likely to be interpreted by the tax authorities in a manner which gives it...
