Inter-company pricing of intangibles – global developments and their impact on your business

The transfer pricing of goods and services between companies and across borders is fundamental to the taxing rights of different countries. The potential for tension and conflict among countries is therefore high. To mitigate the risks this entails, the Organisation for Economic Cooperation and Development (OECD) operates a set of guidelines on the subject (the Transfer Pricing Guidelines for Tax Administrations and Multinational Enterprises), and has recently issued a series of notes regarding profit methods and comparability. Among other things, these guidelines address intangibles and their impact on the pricing of inter-company transactions. In addition, the United States – one of the larger and more influential OECD member countries – has also issued new rules on services transactions, including discussions on certain services that may create intangibles; as well as detailed rules in relation to qualified cost-sharing arrangements (QCSAs) that exist (for US business) separately from the OECD guidelines.

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