Because the actual outcomes and manner in which risks associated with the development or acquisition of an intangible will play out over time are not known with certainty at the time members of the MNE group make decisions regarding intangibles, it is important to distinguish between (a) anticipated (or ex ante) remuneration, which refers to the future income expected to be derived by a member of the MNE group at the time of a transaction; and (b) actual (or ex post) remuneration, which refers to the income actually earned by a member of the group through the exploitation of the intangible.
TPG2017 Chapter VI paragraph 6.44
Category: B. Ownership of intangibles and DEMPE, OECD Transfer Pricing Guidelines (2017), TPG2017 Chapter VI: Special Considerations for Intangibles | Tag: Actual outcome/returns, Ex ante, Ex post, Intangibles, Ownership
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