The transfer pricing methods most likely to prove useful in matters involving transfers of one or more intangibles are the CUP method and the transactional profit split method. Valuation techniques can be useful tools. Supplemental guidance on the transfer pricing methods most likely to be useful in connection with transfers of intangibles is provided below.
TPG2017 Chapter VI paragraph 6.145
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By OECD
Category: OECD Transfer Pricing Guidelines (2017) | Tag: Intangibles, Transfer pricing methods, Transfer pricing methods for intangibles, Valuation
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