TPG2017 Chapter VI paragraph 6.98

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In some situations intangibles or rights in intangibles may be transferred in combination with tangible business assets, or in combination with services. It is important in such a situation to determine whether intangibles have in fact been transferred in connection with the transaction. It is also important that all of the intangibles transferred in connection with a particular transaction be identified and taken into account in the transfer pricing analysis. Examples 23 to 25 in the Annex to Chapter VI illustrate the principles of this paragraph.






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