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Transfer pricing: new guidance on hard to value intangibles

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OECD released the latest edition of its transfer pricing guidelines in January. The guidelines focus the transactional profit split method, hard to value intangibles (HTVI) and financial transactions. Further guidance on HTVI is expected to have considerable impact on transfer pricing compliance. Valuation of intangibles already represents a complex topic with numerous technical challenges. The approved approach allowing tax authorities to rely on ex post analysis of actual outcomes realised after the transaction involving the intangible is likely to result in controversy. Taxpayers are therefore advised to pay particular attention to robustly supporting their transfer pricing of intangibles.

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