Questions often arise regarding the arm’s length compensation for the use of group names, trade names and similar intangibles. Resolution of such questions should be based on the principles of this Section B and on the commercial and legal factors involved. As a general rule, no payment should be recognised for transfer pricing purposes for simple recognition of group membership or the use of the group name merely to reflect the fact of group membership. See paragraph 7.12.
TPG2022 Chapter VI paragraph 6.81
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By OECD
Category: Legal Ownership, OECD Transfer Pricing Guidelines (2022), TPG2022 Chapter VI: Special Considerations for Intangibles | Tag: Contract manufacturing, Group name, Intangibles, Ownership, Payment for use of group name, Pricing intangible transaction, Use of company name, Use of goodwill, Use of trademark
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