Moreover, it should also be noted that access to an assembled workforce with particular skills and experience may, in some circumstances, enhance the value of transferred intangibles or other assets, even where the employees making up the workforce are not transferred. Example 23 in the Annex to Chapter VI illustrates one fact pattern where the interaction between intangibles and access to an assembled workforce may be important in a transfer pricing analysis.
TPG2017 Chapter I paragraph 1.156
Posted on | By OECD
Category: OECD Transfer Pricing Guidelines (2017) | Tag: Access to workforce in place, Assembled workforce, Enhancement of value, Workforce in place
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