Transactional profit split methods may have application in connection with the sale of full rights in intangibles. As with other applications of the transactional profit split method, a full functional analysis that considers the functions performed, risks assumed and assets used by each of the parties is an essential element of the analysis. Where a transactional profit split analysis is based on projected revenues and expenses, the concerns with the accuracy of such projections described in Section D.2.6.4. 1 should be taken into account.
TPG2017 Chapter VI paragraph 6.149
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By OECD
Category: OECD Transfer Pricing Guidelines (2017) | Tag: Application of Profit split method, Intangibles, Profit split method (PSM), Transfer pricing methods
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