Guidance on Transfer Pricing Aspects of Intangibles [electronic resource] /
Organisation for Economic Co-operation and Development.
Organisation for Economic Co-operation and Development,sponsoring body.
Paris : OECD Publishing,
2014.
This document contains revisions to the OECD Transfer Pricing Guidelines to align transfer pricing outcomes with value creation in the area of intangibles. The changes clarify the definition of intangibles and provide guidance for related parties; including transactions involving intangibles and the transfer pricing treatment of local market features and corporate synergies. Some transfer pricing issues relating to intangibles are closely related to other issues that are to be addressed during 2015, most notably in relation to the allocation of risk among MNE group members and recharacterisation of transactions. Because of those interactions some sections of this document are in intermediate form and will be finalised in 2015.
Description based upon print version of record.
Foreword; Table of contents; Abbreviations and acronyms; Executive summary; Bibliography; Amendments to Chapters I - II of the Transfer Pricing Guidelines; Location savings and other local market features; Assembled workforce; MNE group synergies; Example 1; Example 2; Example 3; Example 4; Example 5; Notes; Amendments to Chapter VI of the Transfer Pricing Guidelines; Special considerations for intangibles; Identifying intangibles; Ownership of intangibles and transactions involving the development, enhancement, maintenance, protection and exploitation of intangibles
Transactions involving the use or transfer of intangiblesSupplemental guidance for determining arm's length conditions in cases involving intangibles; Notes; Annex to Chapter VI. Examples to illustrate the guidance on special considerations for intangibles; Example 1; Example 2; Example 3; Example 4; Example 5; Example 6; Example 7; Example 8; Example 9; Example 10; Example 11; Example 12; Example 13; Example 14; Example 15; Example 16; Example 17; Example 18; Example 19; Example 20; Example 21; Example 22; Example 23; Example 24; Example 25; Example 26; Example 27; Example 28; Example 29
Example 30Example 31; Example 32; Example 33; Notes
Includes bibliographical references at the end of each chapters.
This document contains revisions to the OECD Transfer Pricing Guidelines to align transfer pricing outcomes with value creation in the area of intangibles. The changes clarify the definition of intangibles and provide guidance for related parties; including transactions involving intangibles and the transfer pricing treatment of local market features and corporate synergies. Some transfer pricing issues relating to intangibles are closely related to other issues that are to be addressed during 2015, most notably in relation to the allocation of risk among MNE group members and recharacterisation of transactions. Because of those interactions some sections of this document are in intermediate form and will be finalised in 2015.
Corporations
Double taxation.
Double taxation