JTPF report valuation
Report on the Application of Economic Valuation Techniques (2017)
Category: Application of Economic Valuation Techniques within the EU (2016/2017), EU Transfer Pricing Reports | Tag: Accounting valuation, Bargaining power, Calculation of Discount Rates, CAPM, Cost approach, Discount rate, Discounted Cash Flow, Financial projections, Growth rates, Income based approach, Intangibles, Market approach, Relief from Royalty method, Sanity check, TAB, Tax effects, Two-sided method, Useful life, Valuation, Valuation techniques, WACC, WARA
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TPG2017
Chapter VI paragraph 6.177
In this regard, where specific intangibles contribute to continuing cash flows beyond the period for which reasonable financial projections exist, it will sometimes be the case...
TPG2017 Chapter VI paragraph 6.169A key element of some cash flow projections that should be carefully examined is the projected growth rate. Often projections of future cash flows are based...
TPG2017 Chapter VI paragraph 6.161It may be relevant in assessing the reliability of a valuation model to consider the purposes for which the valuation was undertaken and to examine the...
TPG2017 Chapter VI paragraph 6.153In situations where reliable comparable uncontrolled transactions for a transfer of one or more intangibles cannot be identified, it may also be possible to use valuation...
TPG2017 Chapter VI Annex example 28101. Company A is the Parent company of an MNE group with operations in country S. Company B is a member of the MNE group with...
TP case laws
US vs. Amazon, March 2017, US Tax Court