Transfer pricing of intangibles

Intangible assets play a fundamental part of how most businesses create value. As a result, the transfer pricing treatment of intangibles has been at the centre of the OECD’s BEPS project and updated Transfer Pricing Guidelines. These consider both what assets and activities constitute an intangible, its pricing, and what businesses should do where the intangible is hard to value. Businesses must understand and address all of these aspects, and document them clearly, if their transfer pricing of intangible property is to be robust.