For example, a tested party engaged in the marketing and distribution of goods purchased in controlled transactions may have developed marketing intangibles in its geographic area of operation, including customer lists, customer relationships, and customer data. It may also have developed advantageous logistical know-how or software and other tools that it uses in conducting its distribution business. The impact of such intangibles on the profitability of the tested party should be considered in conducting a comparability analysis.
TPG2017 Chapter VI paragraph 6.199
Posted on | By OECD
Category: OECD Transfer Pricing Guidelines (2017) | Tag: Distribution, Intangibles, Limited Risk Distributors (LRD), Local marketing intangibles, Marketing and distribution of goods, Marketing intangibles
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- TPG2022 Chapter VI paragraph 6.199 For example, a tested party engaged in the marketing and distribution of goods purchased in controlled transactions may have developed marketing intangibles in its geographic area of operation, including customer lists, customer relationships, and customer data. It may also have developed advantageous logistical know-how or software and other tools that...
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