Where a local full-fledged operation is converted into an operation assuming limited risk, using limited intangibles and receiving low remuneration, the questions arise of whether this conversion entails the transfer by the restructured local entity to a foreign associated enterprise of valuable intangibles or rights in intangibles and whether there are local intangibles that remain with the local operation.
TPG2017 Chapter IX paragraph 9.64
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By OECD
Category: OECD Transfer Pricing Guidelines (2017) | Tag: Business restructuring, Transfer of intangibles, Transfer of value
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