Tag: Establishing a transaction

TPG2022 Chapter VI Annex I example 20

TPG2022 Chapter VI Annex I example 20

/ Accounting goodwill, Customer lists, Distribution rights, Establishing a transaction, Goodwill, Intangibles, Licence agreement, OECD Transfer Pricing Guidelines (2022), Patents, Purchase Price Allocation (PPA), TPG2022 Annex I to Chapter VI – Examples on Intangibles, Trademark (trade name), Valuation
69. Ilcha is organised in country A. The Ilcha group of companies has for many years manufactured and sold Product Q in countries B and C through a wholly owned subsidiary, Company S1, which is organised in country B. Ilcha owns patents related to the design of Product Q and has developed a unique trademark and other marketing intangibles. The patents and trademarks are registered by Ilcha in countries B and C. 70. For sound business reasons, Ilcha determines that the group’s business in countries B and C would be enhanced if those businesses were operated through separate subsidiaries in each country. Ilcha therefore organises in country C a wholly owned subsidiary, Company S2. With regard to the business in country C: Company S1 transfers to Company S2 the tangible manufacturing and marketing assets previously used by Company S1 in country C. Ilcha and Company S1 agree to terminate the agreement granting Company S1 the following rights with relation to ... Read more
TPG2017 Chapter VI Annex example 20

TPG2017 Chapter VI Annex example 20

/ Customer lists, Distribution rights, Establishing a transaction, Goodwill, Intangibles, Licence agreement, OECD Transfer Pricing Guidelines (2017)
69. Ilcha is organised in country A. The Ilcha group of companies has for many years manufactured and sold Product Q in countries B and C through a wholly owned subsidiary, Company S1, which is organised in country B. Ilcha owns patents related to the design of Product Q and has developed a unique trademark and other marketing intangibles. The patents and trademarks are registered by Ilcha in countries B and C. 70. For sound business reasons, Ilcha determines that the group’s business in countries B and C would be enhanced if those businesses were operated through separate subsidiaries in each country. Ilcha therefore organises in country C a wholly owned subsidiary, Company S2. With regard to the business in country C: Company S1 transfers to Company S2 the tangible manufacturing and marketing assets previously used by Company S1 in country C. Ilcha and Company S1 agree to terminate the agreement granting Company S1 the following rights with relation to ... Read more