Malcolm Joy and Duncan Nott (BDO) explain the new requirements for the robust transfer pricing of intangible assets in the OECD’s updated transfer pricing guidelines.
Tax authorities consider intangible assets to be at the heart of businesses’ value creation. The OECD’s updates to its Transfer Pricing Guidelines in 2017 reflect this with a clear requirement that an arm’s length price should be driven by the economic substance of the intangible assets – its key attributes and management roles – not just ownership of legal title.
The updated guidelines set out a framework for analysing intangibles transactions and expand the disclosure requirements for intangible assets in both the master file and local file elements of transfer pricing documentation.
Businesses will need to have a clear understanding of what their intangible assets are where their value comes from...
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Malcolm Joy and Duncan Nott (BDO) explain the new requirements for the robust transfer pricing of intangible assets in the OECD’s updated transfer pricing guidelines.
Tax authorities consider intangible assets to be at the heart of businesses’ value creation. The OECD’s updates to its Transfer Pricing Guidelines in 2017 reflect this with a clear requirement that an arm’s length price should be driven by the economic substance of the intangible assets – its key attributes and management roles – not just ownership of legal title.
The updated guidelines set out a framework for analysing intangibles transactions and expand the disclosure requirements for intangible assets in both the master file and local file elements of transfer pricing documentation.
Businesses will need to have a clear understanding of what their intangible assets are where their value comes from...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
