When the termination or renegotiation of existing arrangements involves the transfer of something of value (e.g. the termination of a distribution contract is sometimes accompanied by a transfer of intangibles), the guidance at Section E applies to the transfer of something of value, and this section considers whether further compensation may be warranted for any detriments suffered.
TPG2017 Chapter IX paragraph 9.77
Category: F. Indeminification of the restructured entity for the termination of existing arrangements, OECD Transfer Pricing Guidelines (2017), TPG2017 Chapter IX: Transfer Pricing Aspects of Business Restructurings | Tag: Business restructuring, Compensation for termination or renegotiation, Distribution contract, Termination, Transfer of something of value
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- TPG2022 Chapter IX paragraph 9.77When the termination or renegotiation of existing arrangements involves the transfer of something of value (e.g. the termination of a distribution contract is sometimes accompanied by a transfer of intangibles), the guidance at Section E applies to the transfer of something of value,...
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- TPG2022 Chapter IX paragraph 9.75Section F addresses the question of whether the restructured entity, at arm’s length, should receive compensation, in the form of indemnification, upon the termination or substantial renegotiation of its existing arrangements, which may or may not involve a transfer of something of value...