The OECD issues new draft guidance on the transfer pricing of intangibles including: consideration of the identification of intangibles, identification of parties entitled to intangibles income and methods for pricing intangibles. In addition, a new annex contains detailed examples to help both taxpayers and tax authorities in applying transfer pricing to intangibles. The OECD reconsiders the use of safe harbours for certain low-risk transactions, particularly when agreed bilaterally. The OECD seeks input from businesses on the practical consequences of ‘timing issues’ and considers when information is available for use in transfer pricing analyses.
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