It may also be the case that the acquiring business will leverage the existing position of the acquired business to expand the business of the acquirer in the territory of operation of the acquired business by causing the acquired business to use the acquirer’s branding. In that case, consideration should be given to whether the acquirer should make a payment to or otherwise compensate the acquired business for the functions performed, risks assumed, and assets used (including its market position) in connection with expanded use of the acquirer’s name.
TPG2017 Chapter VI paragraph 6.85
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By OECD
Category: OECD Transfer Pricing Guidelines (2017) | Tag: Contract manufacturing, Intangibles, Ownership, Pricing intangible transaction, Use of company name
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