The question arises whether and if so how to take account in the transfer pricing analysis of future events that were unpredictable at the time of the testing of a controlled transaction, in particular where valuation at that time was highly uncertain. The question should be resolved, both by taxpayers and tax administrations, by reference to what independent enterprises would have done in comparable circumstances to take account of the valuation uncertainty in the pricing of the transaction.
TPG2017 Chapter III paragraph 3.72
Category: B. Timing issue in comparability, OECD Transfer Pricing Guidelines (2017), TPG2017 Chapter III: Comparability Analysis | Tag: Comparability analysis, Ex ante, Ex post, Future expectations, Hard-to-value intangibles (HTVI), Highly uncertain, Unpredictable events, Value highly uncertain« Prev | Next »
TPG2017 Chapter III paragraph 3.73