TPG2017 Chapter VI Annex example 5

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Category: OECD Transfer Pricing Guidelines (2017) | Tag: , ,
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13. The facts are the same as in Example 4 except that instead of appreciating, the value of the patents decreases during the time they are owned by Company S as a result of unanticipated external circumstances. Under these circumstances, Company S is entitled to retain the proceeds of the sale, meaning that it will suffer the loss.

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